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    <title>2025 (3) TMI 2077 - ITAT CHENNAI</title>
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    <description>Withholding tax on reinsurance premiums arises only where the remittance is chargeable to tax in India; premiums paid to non-resident reinsurers without an Indian business connection or permanent establishment were therefore not disallowable. Insurance-business income is computed under the special regime for insurers, excluding the ordinary disallowance rules, while actuarially valued IBNR and IBNER claims provisions are deductible as ascertained liabilities. UPS and qualifying commercial vehicles attracted higher depreciation, and substantiated dealer payments and hospital payments routed through third-party administrators remained allowable. For pre-amendment years, minimum alternate tax provisions did not apply to insurance companies, and unauthorised book-profit additions for investment-expenditure disallowance and unexpired-risk reserves were excluded. Treaty-based reduction of dividend distribution tax was not available.</description>
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