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    <title>2026 (1) TMI 547 - ITAT CHENNAI</title>
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    <description>Revision under s.263 was tested issue-wise for an insurer assessed under s.44 read with the First Schedule. On profit on sale of investments, the Tribunal held the AO had made adequate enquiry and the assessee had already included such gains in total income; Rule 5(b)(i) did not justify treating the assessment as erroneous and prejudicial; revision on this issue was set aside. On provision for diminution in value of investments (Rule 5(b)(ii)), the assessee admitted certain debits were not in conformity and the AO had not examined them; revision was upheld. On s.14A r.w. Rule 8D, applying s.44 special regime and prior ITAT view, revision was rejected. On unclaimed policyholder amounts, absence of AO enquiry sustained revision. On s.115JB, IBNR/IBNER and unexpired risk reserve were held ascertained/adequately examined; revision was set aside. Corrigendum introducing a new issue beyond limitation under s.263(2) was quashed.</description>
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    <pubDate>Mon, 05 Jan 2026 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 547 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=784791</link>
      <description>Revision under s.263 was tested issue-wise for an insurer assessed under s.44 read with the First Schedule. On profit on sale of investments, the Tribunal held the AO had made adequate enquiry and the assessee had already included such gains in total income; Rule 5(b)(i) did not justify treating the assessment as erroneous and prejudicial; revision on this issue was set aside. On provision for diminution in value of investments (Rule 5(b)(ii)), the assessee admitted certain debits were not in conformity and the AO had not examined them; revision was upheld. On s.14A r.w. Rule 8D, applying s.44 special regime and prior ITAT view, revision was rejected. On unclaimed policyholder amounts, absence of AO enquiry sustained revision. On s.115JB, IBNR/IBNER and unexpired risk reserve were held ascertained/adequately examined; revision was set aside. Corrigendum introducing a new issue beyond limitation under s.263(2) was quashed.</description>
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