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Rule 330 of Income-tax Rules 2026 — Reserve for Unexpired Risks

Rule 330 of the Income-tax Rules, 2026 caps the reserve for unexpired risks of a non-life insurer at 100% of net premium income for marine insurance and for fire or engineering...

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Updated
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7 answered
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Topic
Income Tax
Published
September 8, 2026
Last updated
Sep 8, 2026
Reading time
6 min
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Last updated: September 2026Applies to: FY 2026-27 (AY 2027-28)Verified against: Government sources

What the rule limits

Sub-rule (1) of rule 330: in computing the profits and gains of any insurance business other than life insurance, the amount carried over to a reserve for unexpired risks — including any amount carried over to any such additional reserve eligible for deduction under paragraph 4(1)(d) of Schedule XIV to the Act — shall not exceed the limits below. The 1962 parallel is rule 6E.

An unexpired risks reserve is the insurer's provision for the portion of premium relating to cover that runs past the year end. It is a genuine liability, but its size is a matter of judgment, so the rule fixes ceilings for tax purposes.

The three ceilings

ClauseClass of insurance businessLimit
(a)Fire insurance or engineering insurance that covers terrorism risks100% of the net premium income of such business of the tax year
(b)Fire insurance or miscellaneous insurance, other than those in clause (a)50% of the net premium income of such business of the tax year
(c)Marine insurance100% of the net premium income of such business of the tax year
Fire insurance appears twice, and terrorism cover decides which limit applies

Rule 330(1) splits fire insurance across clauses (a) and (b), and the dividing line is whether the business covers terrorism risks. Fire cover that includes terrorism attracts the 100% reserve; fire cover that does not is limited to 50%. The same split applies to engineering insurance, which appears in clause (a) only when it covers terrorism, and otherwise falls into clause (b) as miscellaneous insurance. The reason is exposure: terrorism losses are severe, correlated and hard to predict, so a full year's net premium may reasonably be held in reserve. The consequence for an insurer is that the premium ledger has to distinguish terrorism-covering business within each class — a limit computed on undifferentiated fire premium will be wrong in one direction or the other.

Marine insurance takes the full 100% without any qualification, and sub-rule (3)(a) extends it: "marine insurance" includes the Export Credit Insurance. That inclusion is not obvious from the ordinary meaning of the words, and it matters — export credit business is thereby entitled to the 100% ceiling rather than the 50% that would apply if it were treated as miscellaneous insurance.

Net premium income

Sub-rule (3)(b): "net premium income" refers to the premium amount received as reduced by the reinsurance premium paid during the relevant tax year.

The base is net of reinsurance ceded — the reserve follows retained risk

The definition ties the reserve to retained exposure. Premium received is reduced by reinsurance premium paid in the same tax year, so an insurer that cedes most of a large fire account to reinsurers has a small net premium income for that class and correspondingly a small permitted reserve. That is the right answer economically — the unexpired risk it carries is small too. Two points of precision: the reduction is for reinsurance premium paid during the relevant tax year, and the computation is per class of business, since each ceiling in sub-rule (1) is expressed on "the net premium income of such business".

What happens to a disallowed amount

Sub-rule (2): any amount carried over to such reserve or additional reserve which is not allowed as a deduction under this rule in respect of a tax year shall not be included in the total income for the immediately succeeding tax year in the revenue account relating to which the amount is credited.

This prevents the excess being taxed twice. The amount was disallowed when set aside; when it is written back to the revenue account in the following year it is excluded from total income rather than taxed again as a credit. An insurer that disallows an excess reserve and then also offers the write-back to tax has paid tax on the same amount twice.

Worked example

FactsPosition under rule 330
Fire policies covering terrorism; net premium Rs 40 croreReserve up to Rs 40 crore — clause (a)
Ordinary fire policies; net premium Rs 40 croreReserve up to Rs 20 crore — clause (b)
Engineering policies covering terrorism100% — clause (a)
Engineering policies without terrorism cover50% as miscellaneous insurance
Marine hull and cargo business100% — clause (c)
Export Credit Insurance treated as miscellaneousWrong — sub-rule (3)(a) puts it in marine, at 100%
Gross premium Rs 100 crore; reinsurance ceded Rs 70 croreNet premium income is Rs 30 crore
Limit computed on gross premiumOverstated — the base is net of reinsurance paid
Fire premium not split between terrorism and non-terrorismThe limit cannot be computed correctly
Excess reserve disallowed, then written back and offered to taxDouble taxation — sub-rule (2) excludes the write-back

Compliance checklist

  • Confirm the business is insurance other than life insurance before applying rule 330.
  • Include any additional reserve under paragraph 4(1)(d) of Schedule XIV in the amount tested.
  • Split fire and engineering premium between business that covers terrorism risks and business that does not.
  • Apply 100% to terrorism-covering fire and engineering, and to marine.
  • Apply 50% to other fire and to miscellaneous insurance.
  • Treat Export Credit Insurance as marine.
  • Compute net premium income per class, reducing premium received by reinsurance premium paid in the year.
  • Exclude a disallowed amount from total income when it is written back the following year.

Common mistakes

  • Applying one ceiling to all fire business without splitting terrorism cover.
  • Classifying Export Credit Insurance outside marine.
  • Computing the limit on gross premium.
  • Reducing by reinsurance recoveries rather than reinsurance premium paid.
  • Testing the reserve in aggregate rather than class by class.
  • Taxing the write-back of a previously disallowed reserve.

Which year this governs

The Income-tax Rules, 2026 are made under the Income-tax Act, 2025. The 1962 parallel to rule 330 is rule 6E, given for tracing only. Verify the current text and Schedule XIV before computing a reserve.

Quick recapKey facts & short answers

Key Facts About Rule 330

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

What does rule 330 limit?

The amount carried over to a reserve for unexpired risks — including any amount carried to an additional reserve eligible for deduction under paragraph 4(1)(d) of Schedule XIV — in computing profits and gains of an insurance business other than life insurance.

What is the limit for fire or engineering insurance covering terrorism risks?

100% of the net premium income of such business of the tax year.

Choose the tax regime with a calculation, not with a habit.

— TaxClue Direct Tax Desk

Rule 330: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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Questions, answered

Short, direct answers to the 7 questions readers ask most on this topic.

The amount carried over to a reserve for unexpired risks — including any amount carried to an additional reserve eligible for deduction under paragraph 4(1)(d) of Schedule XIV — in computing profits and gains of an insurance business other than life insurance.

100% of the net premium income of such business of the tax year.

50% of the net premium income of such business of the tax year.

100% of the net premium income of such business of the tax year.

Yes. For this rule, "marine insurance" includes the Export Credit Insurance.

The premium amount received as reduced by the reinsurance premium paid during the relevant tax year.

Any amount carried to such reserve or additional reserve which is not allowed as a deduction for a tax year shall not be included in the total income for the immediately succeeding tax year in the revenue account relating to which it is credited.