Section 2 (11) runs thus: 2 (11) Life insurance business ' means the business of effecting contracts of insurance upon human life, including any contract whereby the payment of money is assured on death (except death by accident only) or the happening of any contingency dependent on human life, and any contract which is subject to payment of premiums for a term dependent on human life and shall be deemed to include (a) the granting of disability and double or triple indemnity accident benefits, if so provided in the contract of insurance, (b) the granting of annuities upon human life; and (c) the granting of superannuation allowances and annuities payable out of any fund applicable solely to the relief and maintenance of persons engaged or who have been engaged in any particular profession, trade or employment or of the dependants of such persons; At the outset we would like to dispose of the initial contention raised on behalf of the Revenue that a contract for deferred annuity is quite distinct from a 'policy of insurance ' the expression used in section 5 (1) (vi) since there is no element of insurance against any risk involved in such annuity policy a contention which found favour with the Wealth Tax Officer but was rejected by the Assistant Appellate Commissioner, the Tribunal and the High Court.