SABYASACHI MUKHARJI, J.

( 1 ) THE assessee is a resident company. This reference relates to the question of computation of capital for the super profits tax assessment for the assessment year 1963-64, accounting year of which ended off 30th April, 1962. The assessee filed a return disclosing the chargeable profits at Rs. 37,02,218. While computing the capital base for the purpose of super profits tax, the assessee claimed that the following items should be included in the capital of the company :

. 1. Provision for P. I. Bonus 1,02,200 2. Provision for bonus 39,40,000 3. Provision for gratuity 11,21,742 4. Provision for interest 4,20,482 5. Provision for taxation 68,56,095 6. Works reconstruction reserve 99,75,000 7. Taxation contingency reserve 35,00,000 8. Salom project reserve 80,00,000 9. Niwar project reserve 21,00,000 Rs .

 

( 2 ) THE Super Profits Tax Officer observed that it was clear that the first five items had been set apart for specific purposes already known. He, therefore, held that each of the above items were meant to be used for a specific contingency already foreseen, though not yet quantified, otherwise, those would have all been p

Click Here to Read the rest of this document