Deduction u/s 36(1)(viii) of Income-tax Act, 1961.

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.... finance for industrial or agricultural development in India are entitled to a deduction, in the computation of their taxable profits, of the amount transferred by them out of such profits to a special reserve account, upto a specified percentage of their total income as computed before making any deduction under Chapter VI-A of that Act. This deduction is available only where the financial corpor....

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....to the Department of Banking, vide its U.O. No. 204/35/73-ITA-II, dated 12.11.1973 wherein it was clarified that the percentage would be applied to the total income computed before making any deduction under Chapter VI-A as well as any deduction under section 36(1)(viii) of the Income-tax Act. Thus the above clarification had the effect of negating the earlier instructions of the Board dated 25.11....