Tribunal held that reserves are created as an appropriation out of profit and loss account and terms profit and loss account and general reserves as mentioned in proviso to section 36(1)(viii) cannot be equated with each other. Accordingly balance in profit and loss account, which is not in nature of any other reserve having specific objectives, would not form part of ‘general reserves’ for purpose of proviso to S 36(1)(viii) of the Act.(AY. 2004-05, 2005-06)