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    <title>2015 (9) TMI 488 - ITAT MUMBAI</title>
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    <description>For a life insurance company, reassessment was upheld because the recorded reasons showed escapement of income and the issue of negative reserves had not been examined in the original assessment, so the reopening was not treated as a mere change of opinion. The treatment of negative reserves in computing life insurance profits was not finally sustained and was restored for fresh adjudication in line with the special insurance computation regime and consistency with connected proceedings. Section 14A was held inapplicable to a life insurer governed by the special computation provisions, so the disallowance under that provision was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=263820</link>
      <description>For a life insurance company, reassessment was upheld because the recorded reasons showed escapement of income and the issue of negative reserves had not been examined in the original assessment, so the reopening was not treated as a mere change of opinion. The treatment of negative reserves in computing life insurance profits was not finally sustained and was restored for fresh adjudication in line with the special insurance computation regime and consistency with connected proceedings. Section 14A was held inapplicable to a life insurer governed by the special computation provisions, so the disallowance under that provision was deleted.</description>
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