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    <title>2026 (3) TMI 175 - ITAT KOLKATA</title>
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    <description>For a non-life insurer, income is to be computed under section 44 of the Income-tax Act, 1961 read with the First Schedule, and only expenditure not admissible under sections 30 to 43B can be added back under Rule 5. Management expenditure allocated under the IRDA framework was treated as an accounting and allocation exercise, not as expenditure for an offence or a purpose prohibited by law, so the excess over the regulatory ceiling was not disallowable on that basis alone. Once the underlying addition was deleted, the penalty under section 270A had no independent footing and was cancelled.</description>
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