Insurance Company's IBNR Provisions Based on Actuarial Valuation Allowed as Deduction Under Income Tax Act

HC upheld ITAT's decision regarding insurance company's provision for uncertain liabilities. The court determined that IBNR (incurred but not reported) provisioning cannot be treated as contingent liability when based on IRDA-mandated actuarial valuation methods. Following precedents from Rotork Controls, Metal Box Company, and Bharat Earth Movers cases, the court established that provisions based on actuarial valuation constitute legitimate present obligations arising from past events. The court rejected Revenue's argument of unascertained liability, emphasizing that IRDA-compliant accounting methods and consistent treatment in past assessments support the allowance of such provisions. Appeal was partially admitted only on the question of justification under Section 14A read with Rule 8D(2)(ii). .....

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