https://www.taxtmi.com/caselaws?id=177518 For a life insurance company, section 44 operates as a special overriding code for computing business income under the First Schedule, so a transfer of funds from the shareholders' account to the policyholders' account to cover a deficiency is only an internal movement within the same insurance business and not taxable income. On the same basis, section 14A cannot be superimposed on income computed under section 44, because the special insurance computation excludes the general disallowance mechanism. The settled view applied in the article is that both the inter-account transfer and the section 14A disallowance fail in the insurance context. en-us Fri, 23 May 2014 00:00:00 +0530 Mon, 11 Jan 2016 23:17:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=177518 For a life insurance company, section 44 operates as a special overriding code for computing business income under the First Schedule, so a transfer of funds from the shareholders' account to the policyholders' account to cover a deficiency is only an internal movement within the same insurance business and not taxable income. On the same basis, section 14A cannot be superimposed on income computed under section 44, because the special insurance computation excludes the general disallowance mechanism. The settled view applied in the article is that both the inter-account transfer and the section 14A disallowance fail in the insurance context. Case-Laws Income Tax Fri, 23 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=177518