IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E” MUMBAI BEFORE MS. KAVITHA RAJAGOPAL (JUDICIAL MEMBER)

AND SHRI OMKARESHWAR CHIDARA (ACCOUNTANT MEMBER)

Assessment Year: 2021-22 DCIT Circle 5(3), Kotak Mahindra Life Insurance

426, 4^th Floor, Kautilya Bhawan, Co. Ltd.

BKC, Mumbai - 400051 Vs. 8^th Floor, 12 BKC Bandra Kurla Complex, G- Block, Mumbai – 400051 Maharashtra PAN NO. AAACI 7904G Appellant Respondent Assessee by : Shri Madhur Agrawal a/w. Shri Chetan Kakka Revenue by : Biswanath Das-CIT DR Date of Hearing : 13/11/2024 Date of pronouncement : 01/01/2025 ORDER PER OMKARESHWAR CHIDARA, AM This appeal by the Revenue is directed against order dated

28.05.2024 passed by the Ld. Commissioner of Income-tax (Appeals) – 54 [in short ‘the Ld. CIT(A)’] for assessment year 2021-

22.

2. The revenue filed an appeal in the above said appeal raising following grounds of appeal:

1. "Whether on the facts & circumstances of the case and in law, the Ld. THE LD. CIT(A)(A) erred in interpreting the provisions of Section 44 of the Income Tax, 1961 [“the Act’] read with Rule 2 of the First Schedule along with provisions of Insurance Act, 1938, insurance Regulatory and Development Authority Act, 1999 a