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    <title>2025 (4) TMI 1093 - MADRAS HIGH COURT</title>
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    <description>The Madras HC ruled in favor of the assessee on three key issues regarding insurance business assessment. First, losses on sale of investments were allowed as deductions, following SC precedent in United India Insurance Co. Second, Section 14A disallowance was held inapplicable to insurance companies as Section 44 creates a specialized assessment scheme under First Schedule Rule 5, excluding general business income provisions. Third, provisions for IBNR and IBNER claims were permitted based on actuarial assessments under IRDA regulations. However, the court affirmed the Tribunal&#039;s remand regarding disallowed payments to motor vehicle dealers for verification against CESTAT findings.</description>
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      <link>https://www.taxtmi.com/caselaws?id=769179</link>
      <description>The Madras HC ruled in favor of the assessee on three key issues regarding insurance business assessment. First, losses on sale of investments were allowed as deductions, following SC precedent in United India Insurance Co. Second, Section 14A disallowance was held inapplicable to insurance companies as Section 44 creates a specialized assessment scheme under First Schedule Rule 5, excluding general business income provisions. Third, provisions for IBNR and IBNER claims were permitted based on actuarial assessments under IRDA regulations. However, the court affirmed the Tribunal&#039;s remand regarding disallowed payments to motor vehicle dealers for verification against CESTAT findings.</description>
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