Reliance General Insurance Co. Ltd. v. DCIT

DCIT, CC 6(2), MUMBAI, MUMBAI vs. HDFC ERGO GENERAL INSURANCE COMPANY LIMITED, MUMBAI

In the result, appeal filed by the assesse bearing ITA No

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

…lant also submitted that provisions of section 14A are notapplicable to the assessee engaged in the insurance business. To support the argument, the appellant relied upon various decisions in the case of Bajaj Allianz General Insurance Co. Ltd. v. ACIT (2010) 130 TTJ 398 (Pune Tribunal), JCIT v. Reliance General Insurance Co. [2010] (ITA No.3083, 2950, 2951, 3084, 3085 and 3026/M/2008) (Mumbai Tribunal), ICICI Prudential Life HDFC ERGO General Insurance Company Ltd. Insurance vs ACIT (2012) (ITA No. 6854, 6855, 6856 and 6059/Mum/2010), Kotak Mahindra Old Mutual Life Insurance Company v. ACIT (ITA 2901/Mum/2010) (…

HDFC ERGO GENERAL INSURANCE COMPANY LIMITED,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 6(2), MUMBAI, MUMBAI

In the result, appeal filed by the assesse bearing ITA No

…lant also submitted that provisions of section 14A are notapplicable to the assessee engaged in the insurance business. To support the argument, the appellant relied upon various decisions in the case of Bajaj Allianz General Insurance Co. Ltd. v. ACIT (2010) 130 TTJ 398 (Pune Tribunal), JCIT v. Reliance General Insurance Co. [2010] (ITA No.3083, 2950, 2951, 3084, 3085 and 3026/M/2008) (Mumbai Tribunal), ICICI Prudential Life Insurance vs ACIT (2012) (ITA No. 6854, 6855, 6856 and 6059/Mum/2010), Kotak Mahindra Old Mutual Life Insurance Company v. ACIT (ITA 2901/Mum/2010) (Mum Tribunal) and Birla Sunlife Insurance…

DCIT, MUMBAI vs. ICICI PRUDENTIAL LIFE INSURANCE LIMITED, MUMBAI

…IN THE INCOME TAX APPELLATE TRIBUNAL "C" BENCH, MUMBAI SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No. 2384/MUM/2024 (Assessment Year: 2020-21) ITA No.3003/MUM/2024 (Assessment Year: 2021-22) Deputy Commissioner of Income Tax, Central Circle 6(2), Mumbai Room No.450, 4th Floor, Kautiliya Bhawan, BKC, Mumbai – 400051, Maharashtra. Appellant Vs ICICI Prudential Life Insurance Limited ICICI Prulife Towers, 1089, Appasaheb Marathe Marg, Prabhadevi, Mumbai- 400025, Maharashtra. [PAN: AAAC1735IP] Respondent Appearance For the Appellant/Department : Ms. Madhu Malati Ghosh For the Resp…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 6(2), MUMBAI., MUMBAI vs. ICICI PRUDENTIAL LIFE INSURANCE LIMITED, MUMBAI

…IN THE INCOME TAX APPELLATE TRIBUNAL "C" BENCH, MUMBAI SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No. 2384/MUM/2024 (Assessment Year: 2020-21) ITA No.3003/MUM/2024 (Assessment Year: 2021-22) Deputy Commissioner of Income Tax, Central Circle 6(2), Mumbai Appellant Vs ICICI Prudential Life Insurance Limited Respondent Appearance For the Appellant/Department Ms. Madhu Malati Ghosh For the Respondent/Assessee Ms. Arati Vissanji Date Conclusion of hearing 05.09.2024 Pronouncement of order .12.2024 ORDER Per Rahul Chaudhary, Judicial Member: 1. These are two appeals preferred by the…

DCIT 10(3), MUMBAI vs. RELIANCE LIFE INSURANCE CO. LTD., MUMBAI

In the result, appeal is dismissed”

Bench: Shri B.R. Baskaran (Am) & Shri Ravish Sood(Jm)

…1.3.2016; vii) General Insurance Corp. of India v/s ACIT, ITA no.3554/Mum/ 2011, order dated 15.2.2010; viii) JCIT v/s Reliance General Insurance Co. Ltd., ITA no.3085/ Mum./2008, order dated 26.2.2010; ix) Bajaj Alliance General Insurance Co. Ltd. v/s ACIT, 130 TTJ 398, order dated 31.8.2009; and x) Oriental Insurance Co. Ltd. v/s ACIT, 40 SOT 19, order dated 27.2.2009. 7. We have considered the submissions of the parties and perused the material available on record in the light of the decisions cited before us. Undisputedly, the assessee is engaged in the business of life insurance. The Assessing Officer himse…

DCIT 2(3), MUMBAI vs. TATA AIG LIFE INSURANCE CO. LTD, MUMBAI

In the result, all appeals of the revenue are dismissed and Cross objections are partly allowed

Bench: Shri R C Sharma & Shri Amit Shukla

…आयकर अपीलीय अिधकरण “एच” "यायपीठ मुंबई म"। IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “H”, MUMBAI "ी आर सी शमा", लेखा सद"य एवं "ी अिमत शु"ला, "याियक सद"य के सम" । BEFORE SHRI R C SHARMA, ACCOUNTANT MEMBER AND SHRI AMIT SHUKLA, JUDICIAL MEMBER ITA No. : 1035/Mum/2011 (Assessment year: 2002-03) ITA No.: 1036/Mum/2011 (Assessment year: 2003-04) ITA No.: 1037/Mum/2011 (Assessment year: 2004-05) ITA No.: 1038/Mum/2011 (Assessment year: 2005-06) ITA No.: 1039/Mum/2011 (Assessment year: 2006-07) ITA No.: 1823/Mum/2011 (Assessment year: 2007-08) ITA No.: 4111/Mum/2012 (Assessment year: 2008-09) Addl. CIT 2(3), V…

DCIT 8(3), MUMBAI vs. RELIANCE LIFE INSURANCE COMPANY LTD, MUMBAI

In the result, appeal is dismissed

Bench: Shri Saktijit Dey & Shri Nabin Kumar Pradhan

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, JUDICIAL MEMBER AND SHRI NABIN KUMAR PRADHAN, ACCOUNTANT MEMBER ITA no.5999/Mum./2014 (Assessment Year : 2011–12) Dy. Commissioner of Income Tax Circle–8(3), Aayakar Bhawan ……………. Appellant 101, M.K. Road, Mumbai v/s Reliance Life Insurance Co. Ltd. 10th Floor, R–Tech Park Nirlon Compound, Nr. HUB Mall ……………. Respondent Goregaon (E), Mumbai 400 063 PAN – AADCA1410E Revenue by : Shri Goli Srinivas Rao Assessee by : Shri Jitendra Sanghvi Date of Hearing – 16.08.2016 Date of Order – 24.08.2016 O R D E R PER SAKTIJIT DEY, J.M. Ins…

TATA AIG GENERAL INSURANCE COMPANY LTD,MUMBAI vs. DCIT 2(3), MUMBAI

In the result, appeals of the revenue are dismissed, whereas appeals of the assessee are allowed, in terms indicated hereinabove

…additional grounds are considered as allowed." Following the earlier order of this Tribunal we decide this issue in favour of the assessee.” 15. Ld. AR also placed on record order of the Pune Bench in the case of Reliance General Insurance Co. Ltd. Vs. DCIT, 130 TTJ 398, wherein at para 17 & 18, the Tribunal held as under :- “17. Finally the question to be answered is about the applicability of s.14A in respect of sale of investment which is not taxed under the special circumstances of deletion of a sub-rule from the statute. It is not questioned that the impugned profit was non-taxable per se rather the accepte…

DCIT 2(3), MUMBAI vs. TATA AIG GENERAL INSURANCE CO. LTD, MUMBAI

In the result, appeals of the revenue are dismissed, whereas appeals of the assessee are allowed, in terms indicated hereinabove

…additional grounds are considered as allowed." Following the earlier order of this Tribunal we decide this issue in favour of the assessee.” 15. Ld. AR also placed on record order of the Pune Bench in the case of Reliance General Insurance Co. Ltd. Vs. DCIT, 130 TTJ 398, wherein at para 17 & 18, the Tribunal held as under :- “17. Finally the question to be answered is about the applicability of s.14A in respect of sale of investment which is not taxed under the special circumstances of deletion of a sub-rule from the statute. It is not questioned that the impugned profit was non-taxable per se rather the accepte…

ADDL CIT 2(3), MUMBAI vs. TATA AIG GENERAL INSURANCE CO. LTD, MUMBAI

In the result, appeals of the revenue are dismissed, whereas appeals of the assessee are allowed, in terms indicated hereinabove

…additional grounds are considered as allowed." Following the earlier order of this Tribunal we decide this issue in favour of the assessee.” 15. Ld. AR also placed on record order of the Pune Bench in the case of Reliance General Insurance Co. Ltd. Vs. DCIT, 130 TTJ 398, wherein at para 17 & 18, the Tribunal held as under :- “17. Finally the question to be answered is about the applicability of s.14A in respect of sale of investment which is not taxed under the special circumstances of deletion of a sub-rule from the statute. It is not questioned that the impugned profit was non-taxable per se rather the accepte…

TATA AIG GENERAL INSURANCE COMPANY LTD,MUMBAI vs. ADDL CIT RG 2(3), MUMBAI

In the result, appeals of the revenue are dismissed, whereas appeals of the assessee are allowed, in terms indicated hereinabove

…additional grounds are considered as allowed." Following the earlier order of this Tribunal we decide this issue in favour of the assessee.” 15. Ld. AR also placed on record order of the Pune Bench in the case of Reliance General Insurance Co. Ltd. Vs. DCIT, 130 TTJ 398, wherein at para 17 & 18, the Tribunal held as under :- “17. Finally the question to be answered is about the applicability of s.14A in respect of sale of investment which is not taxed under the special circumstances of deletion of a sub-rule from the statute. It is not questioned that the impugned profit was non-taxable per se rather the accepte…

TATA AIG GENERAL INSURANCE COMPANY LIMITED,MUMBAI vs. ADDL. C.I.T. RANGE 2(3), MUMBAI

In the result, appeals of the revenue are dismissed, whereas appeals of the assessee are allowed, in terms indicated hereinabove

…additional grounds are considered as allowed." Following the earlier order of this Tribunal we decide this issue in favour of the assessee.” 15. Ld. AR also placed on record order of the Pune Bench in the case of Reliance General Insurance Co. Ltd. Vs. DCIT, 130 TTJ 398, wherein at para 17 & 18, the Tribunal held as under :- “17. Finally the question to be answered is about the applicability of s.14A in respect of sale of investment which is not taxed under the special circumstances of deletion of a sub-rule from the statute. It is not questioned that the impugned profit was non-taxable per se rather the accepte…

ADDL CIT 2(3), MUMBAI vs. TATA AIG GENERAL INSURANCE CO. LTD, MUMBAI

In the result, appeals of the revenue are dismissed, whereas appeals of the assessee are allowed, in terms indicated hereinabove

…additional grounds are considered as allowed." Following the earlier order of this Tribunal we decide this issue in favour of the assessee.” 15. Ld. AR also placed on record order of the Pune Bench in the case of Reliance General Insurance Co. Ltd. Vs. DCIT, 130 TTJ 398, wherein at para 17 & 18, the Tribunal held as under :- “17. Finally the question to be answered is about the applicability of s.14A in respect of sale of investment which is not taxed under the special circumstances of deletion of a sub-rule from the statute. It is not questioned that the impugned profit was non-taxable per se rather the accepte…