TaxTMI 
TaxTMI 
2014 (7) TMI 1280
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....d its return of income on 30-10- 2009 declaring total income of Rs. 4,74,32,150/-. During the course of assessment proceedings the AO noted that the assessee has incurred enrolment expenses of Rs. 1,90,22,843/- and claimed the same as Revenue expenditure. The AO noted that these expenses were incurred for preparation of smart cards having the electronic chip. This smart card was prepared under the scheme Rashtriya Swastha Bima Yojana (RSBY) for serving Government Insurance plan for below poverty line (BPL) population. This chip is allotted with details of the BPL family and details of the sum insured. The information of the chip can be downloaded in the hospital while the patient is taking treatment. From the various details furnished by th....
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.... who are beneficiaries identified by the concerned State Governments from BPL families. The smart card has biometric information as well as photograph of the members of the BPL beneficiary family. Beneficiaries under RSBY are entitled to hospitalization coverage upto Rs. 30,000 for one year for up to 5 members of the family. They are also entitled to reimbursement of transport charges of Rs. 1,000 per year. At the time of enrollment, beneficiaries pay Rs. 30 towards registration. Health insurance under the scheme is provided by private or public health insurance companies selected through competitive bidding. These insurance companies are paid premium upto maximum of Rs. 750 per family per year. The scheme is financed primarily by the Centr....
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....ect to the empanelment procedure every year. Therefore, the TPA also could undergo change next year for the particular district in which it enrolled beneficiaries during the year. There is therefore, no enduring benefit which has accrued to the appellant. 16. Further it is seen that the issue of Smart card per se is a completely independent line of business for the appellant company from the main business of settling the beneficiaries claims on behalf of the insurance companies under the RSBY scheme. The appellant has shown the amount received during the year as income and claimed the corresponding expenditure incurred on the printing and issue of the Smart cards. In the event, it is again given the contract in respect of the same ....
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....iture. 4. The learned Commissioner of Income-tax (Appeals) grossly erred in ignoring the provision in the scheme for renewal of policies and also the responsibility of the assessee for supply and maintenance of the smart cards as per the terms and conditions of the scheme, from which it is evident that the expenditure incurred 85 claimed on the making of the smart cards is required to be spread beyond the year under consideration and cannot be treated as relating to the year under consideration alone. 5. For these and such other grounds as may be urged at the time of the hearing, the order of the learned Commissioner of Income-tax (Appeals) may be vacated and that of the Assessing officer be restored. 6. The appel....