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TMI Blog2000 (2) TMI 60X X X X Extracts X X X X X X X X Extracts X X X X ..... dated May 28, 1999, in Income-tax Appeal No. 2915/Bom of 1991 in respect of the assessment year 1987-88. The facts giving rise to this appeal are as follows: In the accounting year 1986-87, the assessee exported goods out of India. It was entitled to deduction under section 80HHC. It was also required to create a reserve to the extent of deduction claimed under the said section. The assessee c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee that under section 80HHC nothing prevented the assessee to create extra reserve in case of deficiency under the above circumstances. It was urged that when the profit and loss account is prepared, the assessee cannot visualise to what extent the profit would increase and in that circumstance, the assessee was entitled to create this extra reserve. This argument was rejected by the Tribunal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... no substantial question of law arises. Before concluding, we may mention that learned counsel for the assessee-appellant next contended that in view of the judgment of the Supreme Court in the case of Shri Shubhlaxmi Mills Ltd. v. Addl. CIT [1989] 177 ITR 193, it was not permissible to create extra reserve after the profit and loss account is finally drawn up. We do not find any merit in the sa ..... X X X X Extracts X X X X X X X X Extracts X X X X
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