Development Rebate Cannot Be Denied Due to Excess Reserve Beyond Statutory Percentage Under Income-Tax Act Guidelines.
The circular clarifies that the development rebate should not be denied if the reserve created exceeds the statutory percentage as specified in the Income-tax Act. The previous circular dated 5-2-1968 was only addressing the computation of a company's capital for super profits tax purposes and not the admissibility of the development rebate itself. It emphasizes that having a reserve greater than the statutory requirement does not violate the requirement to create a reserve equal to the statutory percentage for the development rebate allowance. Misinterpretations suggesting complete denial of the rebate in such cases are incorrect.
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