Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
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Computation of insurance business profits must follow the statutory method under the Income-tax law and First Schedule, with Rule 5 addressing expenditures inadmissible under statutory heads; management expenses reallocated to shareholders under IRDA regulations remain incurred wholly and exclusively for business and are deductible despite exceeding regulatory ceilings. Explanation to the general deductibility rule does not apply where the excess is an accounting reallocation mandated by insurance regulations rather than an unlawful or non-business purpose. Consequently, tax disallowance of such excess management expenses was deleted and any penalty based solely on that addition was cancelled.
Computation of insurance business profits must follow the statutory method under the Income-tax law and First Schedule, with Rule 5 addressing expenditures inadmissible under statutory heads; management expenses reallocated to shareholders under IRDA regulations remain incurred wholly and exclusively for business and are deductible despite exceeding regulatory ceilings. Explanation to the general deductibility rule does not apply where the excess is an accounting reallocation mandated by insurance regulations rather than an unlawful or non-business purpose. Consequently, tax disallowance of such excess management expenses was deleted and any penalty based solely on that addition was cancelled.
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