ITAT quashes reassessment proceedings, allows deductions for reinsurance, depreciation, service payments.

The ITAT annulled the reassessment proceedings under Section 148, citing a lack of failure by the assessee to disclose true facts, deeming it a "change of opinion." It approved deductions for reinsurance premiums to non-residents, 60% depreciation on UPS, and service payments to motor vehicle dealers. It upheld disallowance of depreciation on projectors and addition of long-term insurance premiums. Deductions for IBNR and IBNER provisions were allowed, with Section 14A disallowance deemed inapplicable to insurance companies. The issue of UPR disallowance was remitted for re-adjudication, and the addition under Section 14A for book profits was deleted. The claim for education cess deduction was dismissed. .....

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