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2016 (9) TMI 1418 - ITAT BANGALOREComputation of income from business of life insurance - Manner of computation of income under Section 44 - Held that:- As section 44 of the Act is applied, distinction between various heads of income paled into insignificance. Assessee had in, its return, separately shown the revenue in its shareholders account and revenue derived from its policy holders account. Revenue account for policy holders account clearly reflected the change in valuation of liability in respect of life-policies which were accounted. Surplus/deficit as per shareholders account may be aggregated with surplus/deficit of the policy holders account for determining the income of the assessee u/s. 44 of the Act. - Decided against revenue Not allowing set-off of losses under policyholders' account in accordance with the provisions of Section 70 while computing the total income of the Appellant - Held that:- As we have held that surplus/deficit as per shareholders account should be aggregated with surplus/deficit in the policy holders account for determining the profile/loss in the policy holders account for determining the profile/loss of the assessee u/s 44, and such aggregation would results in a loss of ₹ 34,45,94,000/- as per the impugned order, the view of setting off of losses against income u/s 70,72 would be academic and hence not decided.
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