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    <title>2022 (11) TMI 127 - ITAT MUMBAI</title>
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    <description>Section 44, read with the First Schedule, operates as the special overriding code for computing income of a life insurance business, so dividend income claimed exempt under section 10(34) was governed by that scheme and the assessee succeeded. The Tribunal also held that section 14A and rule 8D do not apply to insurance business income computed under section 44, because the special provision excludes the general disallowance mechanism, and this issue was decided for the assessee. It further held that actuarial surplus under section 44 cannot be disturbed by a separate adjustment for negative reserve, so the addition was unsustainable. The assessee&#039;s position was upheld on all issues.</description>
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    <pubDate>Mon, 31 Oct 2022 00:00:00 +0530</pubDate>
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      <title>2022 (11) TMI 127 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=429703</link>
      <description>Section 44, read with the First Schedule, operates as the special overriding code for computing income of a life insurance business, so dividend income claimed exempt under section 10(34) was governed by that scheme and the assessee succeeded. The Tribunal also held that section 14A and rule 8D do not apply to insurance business income computed under section 44, because the special provision excludes the general disallowance mechanism, and this issue was decided for the assessee. It further held that actuarial surplus under section 44 cannot be disturbed by a separate adjustment for negative reserve, so the addition was unsustainable. The assessee&#039;s position was upheld on all issues.</description>
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      <pubDate>Mon, 31 Oct 2022 00:00:00 +0530</pubDate>
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