Insurance business income under section 44 excludes section 14A disallowance; prohibition-based expense disallowance needs proof of unlawful purpose.

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....Expenditure is disallowable under Explanation 1 to section 37(1) only where it is shown to relate to an offence or an act prohibited by law; because no punitive action had been taken by the competent insurance regulator, the disallowance was deleted. For insurance business income, section 44 with the First Schedule provides a special computation regime that overrides the general computation rules, so section 14A read with Rule 8D does not apply to an insurer. The prior co-ordinate bench view in the assessee's own case was followed.....