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    <title>1946 (4) TMI 24 - CALCUTTA HIGH COURT</title>
    <link>https://www.taxtmi.com/caselaws?id=283653</link>
    <description>Rule 25 applied to a life assurance company assessed on actuarial valuation, and its mutual character did not exclude investment income from the business profits brought into that computation. The company&#039;s investments formed an integral part of its life assurance business, so the assessment had to proceed under the rule rather than under the ordinary heads of income. The doctrine of favourable appropriation could not then be used to set off non-mutual investment receipts first against expenses and leave members&#039; subscriptions as a non-taxable surplus, because the valuation was not based on actual receipts and payments but on a single notional computation of business profits. The claimed allocation was therefore impermissible.</description>
    <language>en-us</language>
    <pubDate>Fri, 12 Apr 1946 00:00:00 +0530</pubDate>
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      <title>1946 (4) TMI 24 - CALCUTTA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=283653</link>
      <description>Rule 25 applied to a life assurance company assessed on actuarial valuation, and its mutual character did not exclude investment income from the business profits brought into that computation. The company&#039;s investments formed an integral part of its life assurance business, so the assessment had to proceed under the rule rather than under the ordinary heads of income. The doctrine of favourable appropriation could not then be used to set off non-mutual investment receipts first against expenses and leave members&#039; subscriptions as a non-taxable surplus, because the valuation was not based on actual receipts and payments but on a single notional computation of business profits. The claimed allocation was therefore impermissible.</description>
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      <pubDate>Fri, 12 Apr 1946 00:00:00 +0530</pubDate>
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