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1991 (4) TMI 167 - AT - Income TaxExtract: .......eet. At any rate, even if it is presumed that there would be excess available out of the retention amounts, there is no further presumption of the same being in the nature of reserves. This contention of the assessee therefore, deserves to be rejected. We do so. 20. In effect, assessee s appeal is partly allowed and Department s appeal is dismissed
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