1991 (2) TMI 39

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..... urance company, assessment for the assessment year 1972-73, the Income-tax Appellate Tribunal has referred to this court the following three questions of law under section 256(1) of the Income-tax Act, 1961 : " (i) Whether the general reserves and taxation reserves are allowable expenditure ? (ii) If question No. 1 is answered in the affirmative, whether such expenditure or allowance would cat .....

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..... Accordingly, here again, following our court's judgment in the case of CIT v. South India Insurance Co. Ltd. [1992] 193 ITR 774 (Appex.), we hold that neither the taxation reserve nor the general reserve can be considered to be an allowance or an expenditure. In view thereof, the second question need not be answered. The third question is answered in the negative and in favour of the assessee. N .....

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