UNITED INDIA INSURANCE CO LTD,CHENNAI vs. PCIT, CHENNAI

ITA 430/CHNY/2022Status: DisposedITAT Chennai05 January 2026AY 2017-1838 pages
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What did the Tribunal hold?

The Tribunal held that the PCIT's order regarding the treatment of unclaimed policyholder funds was justified due to lack of specific enquiry by the AO. However, the Tribunal allowed the assessee's grounds concerning IBNR/IBNER provisions, finding them to be ascertained liabilities, thus quashing the PCIT's revisionary order on this point.

What were the facts?

The assessee claimed exemption under Section 10(38) for profits on sale of investments. The Principal Commissioner of Income Tax (PCIT) initiated revision proceedings under Section 263, holding the assessment order erroneous and prejudicial to revenue. The PCIT also questioned the treatment of unclaimed policyholder funds and provisions for IBNR/IBNER claims.

What were the issues?

Whether the PCIT was justified in revising the assessment order regarding exemption under Section 10(38) and the treatment of unclaimed policyholder funds and IBNR/IBNER provisions.

Which sections of the Income-tax Act were involved?

Section 10(38),Section 263,Section 115JB,Section 37(1)

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Before: Shri S.S. Viswanethra Ravi & Shri Jagadish

For Appellant: Shri S. Sundararaman, CA, Ms. V. Pushpa, Sr. Standing Counsel
For Respondent: Ms. V. Pushpa, Sr. Standing Counsel
Hearing: 07.10.2025Pronounced: 05.01.2026

PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

The appeal in ITA No. 1759/Chny/2019 filed by the assessee is directed against the order dated 29.03.2019 passed by the Id. Principal Commissioner of Income Tax-3, Chennai

The order continues below.

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