The reassessment notice was issued on the ground that the assessee  was wrongly allowed the exemption under section 10 of the Act in respect of income  from dividend from equity shares and interest from tax savings bonds. The petitioner challenged the said notice and order disposing the objection.  Allowing the petition the Court held that in the assessment order dated 18th February, 2016 it is recorded that petitioner has also referred to the judgment of this court in General Insurance Corporation of India v. DCIT (2021) 131 taxmann.com 327 (Bom)(HC) in which this court had occasion to consider whether the exemption granted under Section 10 of the Act were available to insurance company engaged in the business of general insurance and the court had answered in the affirmative. In fact, in the assessment order there is also reference to the portion of the judgment where the court has considered the circular issued by the CBDT to hold that the exemption granted under Section 10 of the Act were available to non life insurance business.  Court also observed that the reassessment notice was issued on the basis of Revenue Audit. Notice and order disposing objection was quashed.  (WP No. 1631 of 2022,dt.18.04.22) (AY. 2013-14)

ECGC Ltd. v. ACIT (Bom.)(HC) (UR)