The Tribunal held that the computation of income of insurance companies is governed by the special provisions of section 44. Accordingly, section 14A and rule 8D have no application while computing the taxable income of an insurance company.  The Tribunal held that amounts representing reserve for unexpired premium which had already been disallowed in earlier years could not again be brought to tax in the year under consideration. The matter was restored to the Assessing Officer for verification and appropriate relief.  (AY. 2008-09 to 2014-15).