1984 (10) TMI 15

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....he Universal Fire and General Insurance Co. Ltd., Bombay. Today, after nationalisation of general insurance business, it is one of the subsidiary units of the United India Insurance Co. Ltd. The Assistant General Manager of the United India Insurance Co. Ltd. has addressed a letter dated September 25, 1984, to the Central Government Advocate stating that the assessee (as now amended) is not intere....

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....l Reserves ". These reserves were actually reserves for unexpired risks consisting of three items, viz. 1. Rs. 99,955.51 pertaining to marine insurance. 2. Rs. 9,68,482.79 pertaining to accident and miscellaneous insurance. 3. Rs. 14,30,014.61 pertaining to fire insurance. The Income-tax Officer has refused to include the said sum of Rs. 24,98,452 while computing the capital base in accordance....

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....urther opinion that the said expression " fund " not having been defined in the said Act, it was to be given its plain ordinary dictionary meaning. Giving such a meaning, the expression " fund " meant a sum of money available to the assessee for payment or discharge of an unexpected claim. Accordingly, the Tribunal held that the reserves for unexpired risks clearly represented a sum of money avail....