Tribunal held that unless a branch was established in India, non-resident insurance company could not do any business after 2014—Thus, profit of non-resident re-insurance company was taxable in India and hence, assessee was liable to deduct tax u/s 40(a)(i).AO rightly disallowed re-insurance premium. (AY. 2003-04 to 2010-11 )
ACIT v. United India Insurance Co. Ltd. (2018) 67 ITR 191 /195 TTJ 65 (UO) (Chennai)(Trib.)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Re-insurance Premium—Liable to deduct tax at source– Disallowance is held to be justified.