Life insurance maturity proceeds remain exempt where section 10(10D) does not restrict the insurer to India.

Section 10(10D) exempts any sum received under a life insurance policy, and that exemption is confined only by the specific statutory exceptions in the provision. The absence of the word "insurer" in section 10(10D) meant the benefit could not be limited to policies issued by an Indian insurer, and the definition in section 2(28BB) was held irrelevant for narrowing the exemption. Accordingly, maturity proceeds under a life insurance policy issued by a foreign insurance company were exempt and not taxable in the assessee's hands.

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Issues: Whether the maturity proceeds received under a life insurance policy taken from a foreign insurance company were exempt under section 10(10D) of the Income-tax Act, 1961, or taxable on the footing that the policy was not issued by an Indian insurer.

Analysis: Section 10(10D) grants exemption to any sum received under a life insurance policy, subject only to the specific exceptions stated in the provision. The term "insurer" does not appear in section 10(10D), and the definition of "insurer" in section 2(28BB) was held to be irrelevant for restricting the scope of that exemption. Since the legislature had not limited the benefit to policies issued only by Indian insurance companies, the provision could not be narrowed by implication.

Conclusion: The maturity amount received under the life insurance policy was exempt under section 10(10D) and was not taxable in the assessee's hands.

Ratio Decidendi: Where a taxing exemption provision grants benefit on receipt under a life insurance policy without restricting the issuing insurer to an Indian insurer, the exemption cannot be curtailed by importing words not found in the text of the provision.

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