KARAMCHAND PREMCHAND PVT. LTD. vs. COMMISSIONER OF INCOME TAX, GUJARAT

Accordingly fails and is dismissed

23A of the Income Tax Act, 1922) was indeed a provision and not a reserve. The assessee Itself called it a provision. It did not call it a reserve nor was the amount set apart or appropriated as a reserve. It is not to suggest that the description given or the Book entries made by the assessee are conclusive

COMMISSIONER OF INCOME-TAX, WEST BENGAL,CALCUTTA vs. GUNGADHAR BANERJEE AND CO. (P) LTD

In the result we hold that the order of the High Court is