Life insurance premium deduction for major children upheld under the plain meaning of "any child" in tax law.

An individual assessee may claim deduction for life insurance premia paid on policies taken on the lives of her children even after they attain majority, because section 80C(2)(a)(i) refers to "any child" without limiting the relief to a minor child. The contrast with section 64(1)(iii), which expressly uses the word "minor," supports the view that Parliament did not intend an age restriction in this deduction provision. The commentary and departmental circular considered in the article also support this reading. On that basis, the deduction was allowable and the disallowance was unsustainable.

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Issues: Whether an individual assessee is entitled to deduction under section 80C(2)(a)(i) of the Income-tax Act, 1961 for life insurance premia paid on policies taken on the lives of her children after they attained majority.

Analysis: The provision allows deduction for sums paid by an individual to keep in force insurance on the life of the assessee or on the life of the wife, husband or any child of the assessee. On a plain reading, the expression "any child" is not restricted to a minor child. The absence of a qualifying word such as "minor" in section 80C(2)(a)(i), contrasted with the use of that word in section 64(1)(iii), supports the conclusion that the Legislature did not intend to confine the deduction to premia paid during the child's minority. The departmental circular and the commentary relied upon also indicate that the relief was meant to extend to premiums on policies on the life of any child, whether minor or major.

Conclusion: The assessee was entitled to the deduction and the disallowance was not sustainable.

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