https://www.taxtmi.com/caselaws?id=5504 A refund of income-tax received by the Life Insurance Corporation, attributable to tax paid by its predecessor before nationalisation, was held deductible in computing life insurance profits under rule 2(1)(b) of the First Schedule to the Income-tax Act, 1961. The Court applied the statutory fiction in section 7 of the Life Insurance Corporation Act, 1956, which vested all assets and liabilities of the existing insurers in the Corporation, and held that the fiction must be carried to its logical end. Because the refund arose from the predecessor's transferred tax payments, it was treated as part of the inherited opening balance and, by implication, as included in the earlier inter-valuation period. The question was answered in the affirmative, in favour of the assessee. en-us Mon, 19 Feb 1996 00:00:00 +0530 Tue, 25 Nov 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5504 A refund of income-tax received by the Life Insurance Corporation, attributable to tax paid by its predecessor before nationalisation, was held deductible in computing life insurance profits under rule 2(1)(b) of the First Schedule to the Income-tax Act, 1961. The Court applied the statutory fiction in section 7 of the Life Insurance Corporation Act, 1956, which vested all assets and liabilities of the existing insurers in the Corporation, and held that the fiction must be carried to its logical end. Because the refund arose from the predecessor's transferred tax payments, it was treated as part of the inherited opening balance and, by implication, as included in the earlier inter-valuation period. The question was answered in the affirmative, in favour of the assessee. Case-Laws Income Tax Mon, 19 Feb 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5504