DCIT CEN 5 3, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

ITA 1682/MUM/2025Status: DisposedITAT Mumbai26 September 2025AY 2017-18Bench: SHRI OM PRAKASH KANT (Accountant Member), SHRI RAJ KUMAR CHAUHAN ( (Judicial Member)26 pages
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What did the Tribunal hold?

The Tribunal held that the disallowance under Section 14A read with Rule 8D is upheld, reversing the CIT(A)'s finding. The appeals of the Revenue were allowed partly, while the assessee's application under Rule 27 was dismissed.

What were the facts?

The assessee, an insurance company, claimed exemption for interest, dividend, and long-term capital gains. The Assessing Officer (AO) argued that Section 44 of the Income Tax Act mandates computation of income strictly as per the First Schedule, treating investment income as business profit. The AO also proposed disallowance under Section 14A for expenses related to exempt income.

What were the issues?

Whether income from investments claimed as exempt under Section 10 is to be treated as business income under Section 44, and whether expenses related to earning exempt income are disallowable under Section 14A.

Which sections of the Income-tax Act were involved?

Section 10(15),Section 10(34),Section 10(38),Section 44,Section 148,Section 148A,Section 14A

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Income Tax Appellate Tribunal, MUMBAI BENCH “C” MUMBAI

Before: SHRI OM PRAKASH KANT & SHRI RAJ KUMAR CHAUHAN

For Appellant: Mr. Anish Thackar, Mr. R A Dhyani, CIT DR &
For Respondent: Mr. V.S. Mahajan, Sr. DR
Pronounced: 26/09/2025

PER BENCH

These appeals by the Revenue are directed against a consolidated order dated 09.01.2025 passed by the Ld. Commissioner of Income-tax (Appeals) – 54, Mumbai, for assessment year 2012-13, 2015-16, 2016-17 and 2017-18 respectively. As common issue-in-dispute is involved in all those

ICICI Lombard General Insurance Co. Ltd., ICICI Lombard General Insurance Co. Ltd., way of this consolidated order for the sake of convenience. way of this consolidated order for the sake of convenience. way of this consolidated order for

The order continues below.

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