https://www.taxtmi.com/caselaws?id=766641 The ITAT Chennai allowed the assessee's appeal on multiple grounds. The tribunal permitted provisions for IBNR/IBNER claims, holding that liabilities ascertainable through empirical data or known methodology cannot be treated as contingent liabilities, following SC precedent in Rotork Controls. However, the tribunal ruled against the assessee regarding amortization of premium paid on securities, following its own coordinate bench decision. The tribunal favored the assessee on disallowance under section 40(a)(i) for reinsurance premium paid to foreign insurers, directing the AO to delete additions and setting aside the CIT(A)'s restriction to 15% of payments. Similarly, disallowances for commission paid to non-resident agents and survey fees paid to non-residents were decided in favor of the assessee, as no actual payments were made by the assessee requiring tax deduction, and services were rendered outside India with no business connection in India. en-us Fri, 31 Jan 2025 00:00:00 +0530 Mon, 21 Jul 2025 13:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766641 The ITAT Chennai allowed the assessee's appeal on multiple grounds. The tribunal permitted provisions for IBNR/IBNER claims, holding that liabilities ascertainable through empirical data or known methodology cannot be treated as contingent liabilities, following SC precedent in Rotork Controls. However, the tribunal ruled against the assessee regarding amortization of premium paid on securities, following its own coordinate bench decision. The tribunal favored the assessee on disallowance under section 40(a)(i) for reinsurance premium paid to foreign insurers, directing the AO to delete additions and setting aside the CIT(A)'s restriction to 15% of payments. Similarly, disallowances for commission paid to non-resident agents and survey fees paid to non-residents were decided in favor of the assessee, as no actual payments were made by the assessee requiring tax deduction, and services were rendered outside India with no business connection in India. Case-Laws Income Tax Fri, 31 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766641