VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.44 and the First Schedule: what the opening non-obstante words displace, Rule 2 for life insurance and Rule 5 for general insurance
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.44First ScheduleRule 1 of the First ScheduleRule 2 of the First ScheduleRule 4 of the First ScheduleRule 5 of the First ScheduleRule 6 of the First ScheduleRule 6Es.43Bs.199

Statutory position — s.44 and the First Schedule: what the opening non-obstante words displace, Rule 2 for life insurance and Rule 5 for general insurance

My client is an insurance company and the Assessing Officer has computed its income head by head, disallowing items under sections 14A, 37 and 45. Is that computation open to him at all?

My client is an insurance company and the Assessing Officer has computed its income head by head, disallowing items under sections 14A, 37 and 45. Is that computation open to him at all?

No, not on that footing. Section 44 begins "Notwithstanding anything to the contrary contained in the provisions of this Act relating to the computation of income chargeable under the head 'Interest on securities', 'Income from house property', 'Capital gains' or 'Income from other sources', or in section 199 or in sections 28 to 43B", and directs that the profits and gains of any business of insurance — including such a business carried on by a mutual insurance company or by a co-operative society — shall be computed in accordance with the rules contained in the First Schedule. That non-obstante clause is the whole point of the section: it takes the four other heads of income out of play, takes section 199 out of play, and takes the ordinary business-computation machinery of sections 28 to 43B out of play, leaving the First Schedule as the exclusive code. Rule 2 computes life insurance profits as the annual average of the actuarial surplus; Rule 5 computes general insurance profits as the profit before tax and appropriations disclosed in the regulatory profit and loss account, subject only to the adjustments the rule itself lists.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text), reported as Income-tax Act, 1961, s.44, as printed on the departmental Year 2012 edition (incometaxindia.gov.in/w/section-44-9), the Year 2009 edition (/w/section-44), the Year 2006 edition (/w/section-44-16), the Year 2002 edition (/w/section-44-4) and the Year 2000 edition (/w/section-44-1). The First Schedule as printed on the Year 2024 (No. 1) edition (/w/first-schedule-17), the Year 2020 edition (/w/first-schedule-12), the Year 2014 edition (/w/first-schedule-1) and the Year 2013 edition (/w/first-schedule). Rule 6E of the Income-tax Rules, 1962 at incometaxindia.gov.in/w/rule-6e. It bears on section 44, section First Schedule, section Rule 1 of the First Schedule, section Rule 2 of the First Schedule, section Rule 4 of the First Schedule, section Rule 5 of the First Schedule, section Rule 6 of the First Schedule, section Rule 6E, section 43B, section 199 of the Income Tax Act 1961, in Deductions & Disallowances, How Tax Law Is Read and Assessment & Scrutiny matters.

Validity check could not be completed. Validity check could not be completed, and the reason matters. Rules 2 and 5 of the First Schedule are corroborated on four departmental editions running to Year 2024 (No. 1), which is close to current. Section 44 itself is corroborated on thirteen editions running to Year 2013 (/w/section-44-12), all identical, and its only amendment footnote dates the present words to the Direct Tax Laws (Amendment) Act, 1987 with effect from 1 April 1989. I could not read an edition later than Year 2013, so I cannot certify from a departmental source that nothing has been done to the section since; that is why the label is 'unverified' and not 'good law'. Nothing read on this pass suggests any change, and the section is reproduced in the same terms in the Tribunal proceedings read for this batch, but a reader arguing a current year should satisfy himself on the point. I did not carry out any survey of judicial treatment of section 44 or of the First Schedule beyond the Kolkata Tribunal's order in DCIT v. National Insurance Co. Ltd., which is in this library under its own entry and which refers to two Supreme Court decisions — General Insurance Corporation of India v. CIT (1999) 240 ITR 139 (SC) and CIT v. Oriental Fire & General Insurance Co. Ltd. (2007) 291 ITR 370 (SC) — that I have NOT read and do not vouch for beyond noting that they were cited.

Why it matters

Once the non-obstante clause is understood, most of the standard assessment-order arsenal falls away for an insurer. There is no separate head of capital gains on the insurer's investments, no separate head of income from other sources, no house-property computation, and no free-standing application of the sections 28 to 43B code. For general insurance the arithmetic starts from a figure the assessee did not choose — the profit before tax and appropriations as disclosed in the profit and loss account PREPARED IN ACCORDANCE WITH the Insurance Act, 1938 or the rules made thereunder or the Insurance Regulatory and Development Authority Act, 1999 or the regulations made thereunder — and the Assessing Officer's power is confined to the three adjustments in Rule 5: (a) adding back expenditure or allowance, including any amount debited to the profit and loss account by way of a provision for tax, dividend, reserve or any other prescribed provision, which is not admissible under sections 30 to 43B; (b) adding or deducting gain or loss on realisation of investments not already credited or debited, and adding back any provision for diminution in the value of investment debited to the profit and loss account; and (c) allowing as a deduction such amount carried over to a reserve for unexpired risks as may be prescribed — that prescription being Rule 6E of the Income-tax Rules, 1962, which caps the reserve at 100 per cent of net premium income for fire or engineering insurance providing terrorism cover, 50 per cent for other fire or miscellaneous insurance, and 100 per cent for marine insurance. A proviso added to Rule 5 allows a sum added back under clause (a) as a section 43B item to be deducted in the year it is actually paid. For life insurance the base is the actuarial surplus disclosed by the valuation under the Insurance Act, 1938, taken as the annual average of the surplus for the last inter-valuation period ending before the commencement of the assessment year, adjusted to exclude any surplus or deficit made in an earlier inter-valuation period; and Rule 1 requires life insurance profits to be computed separately from any other business. Keep the vocabularies apart: the "actuarial surplus" is a concept of the insurance regulatory code and the tax rule adopts it; it is not a tax concept in its own right, and the adjustments the tax rule permits are the only ones a tax officer may make.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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