https://www.taxtmi.com/caselaws?id=200797 In computing taxable income of a non-resident life assurance business, the Burma branch apportionment was made by reference to premium income of the previous year, because the tax scheme charged income for that year and the actuarial rules could not displace annual assessment. Interim bonus paid to policyholders was treated as a distribution out of, or in anticipation of, profits and therefore formed part of the divisible surplus for the valuation period; it was not deductible as expenditure incurred in earning profits. The result was that both substantive questions were resolved in favour of Revenue, with one judge dissenting only on the first issue. en-us Wed, 11 Jun 1941 00:00:00 +0530 Mon, 23 Apr 2018 18:53:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=200797 In computing taxable income of a non-resident life assurance business, the Burma branch apportionment was made by reference to premium income of the previous year, because the tax scheme charged income for that year and the actuarial rules could not displace annual assessment. Interim bonus paid to policyholders was treated as a distribution out of, or in anticipation of, profits and therefore formed part of the divisible surplus for the valuation period; it was not deductible as expenditure incurred in earning profits. The result was that both substantive questions were resolved in favour of Revenue, with one judge dissenting only on the first issue. Case-Laws Income Tax Wed, 11 Jun 1941 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=200797