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    <title>2015 (2) TMI 316 - ITAT DELHI</title>
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    <description>In insurance business, income must be computed under section 44 read with Rule 5 of the First Schedule, and section 14A cannot be applied in the same manner; the Tribunal deleted the disallowance on that basis. The transfer pricing adjustment on facultative reinsurance commission was found to rest on inadequate comparative material between treaty and facultative reinsurance, so additional evidence was admitted and the issue was remitted for fresh adjudication. The disallowance of expenses under section 37 was also set aside and restored to the Assessing Officer in line with the assessee&#039;s own earlier case. The assessee obtained partial relief, with one disallowance deleted and the other issues sent back for reconsideration.</description>
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    <pubDate>Mon, 15 Dec 2014 00:00:00 +0530</pubDate>
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      <title>2015 (2) TMI 316 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=256316</link>
      <description>In insurance business, income must be computed under section 44 read with Rule 5 of the First Schedule, and section 14A cannot be applied in the same manner; the Tribunal deleted the disallowance on that basis. The transfer pricing adjustment on facultative reinsurance commission was found to rest on inadequate comparative material between treaty and facultative reinsurance, so additional evidence was admitted and the issue was remitted for fresh adjudication. The disallowance of expenses under section 37 was also set aside and restored to the Assessing Officer in line with the assessee&#039;s own earlier case. The assessee obtained partial relief, with one disallowance deleted and the other issues sent back for reconsideration.</description>
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      <pubDate>Mon, 15 Dec 2014 00:00:00 +0530</pubDate>
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