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Special Reserve Transfers: Profits Still Count as Income Under RBI Guidelines.

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Full Text of the Document

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....Scope of total income - Exclusion of amount transferred to special reserve - That special reserve belongs to the assessee only and is reserved for utilization in certain eventualities for the safety and benefit of assessee and its customers as per the RBI guidelines. This fund is in the type of savings that belongs to the assessee itself. Therefore, it cannot be said that transfer of certain profits to reserve fund will not fall in the definition of income of the assessee - AT....