https://www.taxtmi.com/caselaws?id=458949 ITAT Chennai allowed assessee's appeal regarding TDS under section 195, holding that reinsurance premium ceded to non-resident reinsurers is not taxable in India under Income Tax Act or DTAA, thus no disallowance under section 40(a)(i) for non-deduction of TDS. Court upheld disallowance of IBNR/IBNER provisions as unascertained liability not deductible under section 37(1), but restricted disallowance to amounts debited to profit and loss account. MAT computation issues regarding IBNR/IBNER provisions were remanded to AO for fresh adjudication. Court deleted section 14A disallowance while computing book profit under section 115JB, following Special Bench decision. Various other grounds including PF contribution delays and infra payments were decided based on established precedents. en-us Fri, 19 Jul 2024 00:00:00 +0530 Tue, 19 Nov 2024 16:32:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=458949 ITAT Chennai allowed assessee's appeal regarding TDS under section 195, holding that reinsurance premium ceded to non-resident reinsurers is not taxable in India under Income Tax Act or DTAA, thus no disallowance under section 40(a)(i) for non-deduction of TDS. Court upheld disallowance of IBNR/IBNER provisions as unascertained liability not deductible under section 37(1), but restricted disallowance to amounts debited to profit and loss account. MAT computation issues regarding IBNR/IBNER provisions were remanded to AO for fresh adjudication. Court deleted section 14A disallowance while computing book profit under section 115JB, following Special Bench decision. Various other grounds including PF contribution delays and infra payments were decided based on established precedents. Case-Laws Income Tax Fri, 19 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=458949