https://www.taxtmi.com/caselaws?id=69043 The Tribunal ruled in favor of the assessee, holding that only annuities received could be assessed as income, not the premium paid for annuity policies. The introduction of a guarantor did not imply constructive receipt of premium by the assessee, as the guarantor's liability was to pay the remaining premium to the insurer, not the assessee. The Tribunal found no violation of CBDT Circular No. 1310 and concluded that the Commissioner failed to establish a case for taxing the amount received by the guarantor as the assessee's income. The appeal was allowed, canceling the Commissioner's order and upholding the assessment based on the tax treatment of annuities. en-us Tue, 16 Apr 1991 00:00:00 +0530 Mon, 04 Apr 2011 17:27:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=69043 The Tribunal ruled in favor of the assessee, holding that only annuities received could be assessed as income, not the premium paid for annuity policies. The introduction of a guarantor did not imply constructive receipt of premium by the assessee, as the guarantor's liability was to pay the remaining premium to the insurer, not the assessee. The Tribunal found no violation of CBDT Circular No. 1310 and concluded that the Commissioner failed to establish a case for taxing the amount received by the guarantor as the assessee's income. The appeal was allowed, canceling the Commissioner's order and upholding the assessment based on the tax treatment of annuities. Case-Laws Income Tax Tue, 16 Apr 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=69043