THE ACIT,CIR-1(1),, TRIVANDRUM vs. M/S.US TECHNOLOGY INTERNATIONAL P. LTD, TRIVANDRUM

Per CHANDRA POOJARI, AM:

This appeal by the Revenue and the Cross Objection by the assessee are directed

order of the CIT(A), Trivandrum dated 22/02/2018 and pertains to the assessment

year 2009-10.

1.1 At the time of hearing, the Ld. AR made an endorsement that the assessee is

not interested in pursuing the Cross Objection in C.O. No.47/Coch/2019. Hence,

the Cross Objection filed by the assessee is dismissed as withdrawn.

Tribunal. The Ld. DR has filed a condonation petition accompanied by an affidavit

stating that the order of the CIT(A), Trivandrum dated 22/02/2018 in the case of

the assessee herein for the assessment year 2009-10 was received in the O/o

Principal Commissioner of Income-tax on 23/02/2018. The Ld. DR submitted that

as such, an appeal against the said order should have been filed on or before

24.04.2018. According to the Ld. DR , as per the said order, it was noticed that

CIT(A) erred in holding that the assessee is eligible for alternate claim of deduction

u/s. 10A of the Act.

2.1 It was submitted that the CIT(A) ought to have noted that section 10A(5) of

the Income-tax Act stipulates that the deduction u/s. 10A shall not be admissible 2

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unless the assessee furnished Form No. 56F alongwith the return of income, by

which the tax effect is Rs.14,56,56,499/-. Hence, vide this order in C. No.

404/J/8/2018 dated 17/04/2018, the Principal Commissioner of Income-tax,

Thiruvananthapuram had directed the Deputy Commissioner to file an appeal

against the impugned order. It was submitted that as directed by the Principal

Commissioner of Income-tax, Thiruvananthapuram, all the required documents

were sent to the office of the Commissioner of Income-tax(DR) on 20/04/2018. It

was submitted that inadvertently, both the tapals were delivered to the office of the

Commissioner of Income-tax(DR) and both copies were retained there on the

impression that it pertains to that office. Later on, it was learnt that this case had

not been filed before the ITAT and subsequently, vide letter dated 31/07/2019,

Commissioner of Income-tax(DR), ITAT, Kochi directed this office to file the appeal

afresh with necessary condonation petition after completing the formalities from the

higher authorities. According to the Ld. DR, on that basis this office had once

again obtained an order u/s. 253(2) from the Principal Commissioner of Income-tax,

Thiruvananthapuram on 26/08/2019. Thus, there was delay of 49 day.

Accordingly, it was prayed that it is only just and reasonable that the delay was

condoned, and the appeal was heard on merits.

2.2 We have gone through the condonation petition filed by the Department. As

seen from the records, both the copies of required documents relating to the filing

of the appeal were inadvertently sent to the office of the Commissioner of Income-

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tax(DR), ITAT, Kochi instead of the Commissioner of Income-tax(Appeals),

Trivandrum. We find that reasons advanced by the Department is bona fide and

there is good and sufficient cause for belatedly filing the appeal before the Tribunal.

Accordingly, the delay of 496 days in filing the appeal is condoned and the appeal is

admitted for adjudication.

(i) Q Burst Technologies Pvt. Ltd. – AYs 2008-09 and 2010-11 (ii) Paragon Biomedical India Pvt. Ltd. – AYs 2010-11 and 2011-12

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4.1 The second ground is with regard to allowance of deduction u/s. 10A of the I.T. Act.

u/s. 10B has not been entertained during the course of assessment proceedings,

the assessee made an alternative claim of deduction u/s. 10A of the Act by filing a

revised return but the same has not been entertained by the Assessing Officer as

there was no consistency in the claim of deduction and not supported by recognized

certification. The assessee filed Form No. 56F dt.17.02.2016 making a claim of

deduction u/s 10A of a sum of Rs.34,76,09,469/-. The assessee has also filed

another Form No.56F dt. 17.04.2017 claiming a different amount of

Rs.36,08,47,424/- to be allowed as deduction u/s 10A. By virtue of the provisions of 5

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section 10A(5) deduction u/s 10A is allowable only if the prescribed form i.e. Form

No. 56F along with the report of the accountant certifying that the deduction has

correctly been claimed in accordance with the provisions of the section, is filed

along with the return of income. Since the assessee neither had filed the return

claiming the deduction u/s 10A nor filed Form No.56F along with the return,

ordinarily the claim of deduction cannot be allowed in accordance with the decision

of the Supreme Court in the case of Goetze (India) Ltd Vs CIT (284 ITR 323) as

claim of deduction not been made in the original return filed cannot be entertained

unless a valid revised return is filed. Thus, filing a return along with Form No.56F is

the must for claiming fresh deduction u/s 10A but in the absence of such return

been filed before the CIT(A), whether the fresh claim made now could be

entertained or not is the question to be answered first. To answer this question, the

CIT(A) relied on the decision of the Hon'ble ITAT, Cochin Bench in the case of CWP

Taylor Vs DCIT for the Asst. Year 2004-05 in ITA No.695/Coch/2008 dated

28.07.2009 wherein it was held as follows:

"We have heard rival submissions. No doubt, in the case of Goetze (India) Ltd. 284 ITR 323 the Apex Court held that an assessee could not make a claim for deduction before the Assessing Officer otherwise than by fling a revised return. Hon'ble Apex Court distinguished its own decision in the case of National Thermal Power Corporation Vs. CIT (Supra) by mentioning that the question there was regarding the power of the Tribunal u/s 254 of the Act to entertain, for the first time, a point of law, provided the facts on the basis of which the issue could be raised were there before the Tribunal. Their Lordships specifically held that its decision did not impinge the power of the Tribunal to entertain first time a point of law provided the facts on the basis of which the issue is raised is there on record. This decision of Hon'ble Apex Court is limited to the power of assessing authorities for considering a claim made by the assessee which was originally not there in the return".

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"In our opinion, though the assessing officer could not entertain the claim made by the assessee otherwise than through a revised return, nothing prevented the learned Commissioner of Income-tax (Appeals) from considering the claim of the assessee, which the assessee had specifically, raised in its ground of appeal in view of the decision of the Hon'ble Apex Court in NTPC's case referred supra."

5.1 In the background of forgoing, according to the CIT(A), it was clarified

beyond doubt that the first appellate authority can entertain the fresh claim of

deduction made u/s 10A subject to raising the issue in the grounds of appeal and

the facts on the basis of which the issue could be raised are readily available before

the first appellate authority. Further, various Courts have held that powers of the

CIT(A) is co-terminus with that of the Assessing Officer. Thus, the CIT(A) went

ahead with verifying the claim of deduction made u/s 10A as the assessee had

already raised this issue in the grounds of appeal and facts are more or less same

for the claim of deduction either u/s 10B or u/s 10A of the Act.

5.2 With regard to the eligibility to claim deduction, the CIT(A) observed that

Section 10A(2) of the Act assumes significance, which reads as follows,

This section applies to any undertaking which fulfills all the following

conditions, namely,

(i) It has begun or begins to manufacture or produce articles or things or computer software during the previous year relevant to the assessment year. (a) commencing on or after the 1st day of April, 1981, in any free trade zone; or

I.T(TP).A. No. 514Coch/2019 & C.O. No.47/Coch/2019 (b) commencing on or after the 1st day of April, 1994, in any electronic hardware technology park, or, as the case may be, software technology park; (c) commencing on or after the 1st day of April, 2001 in any special economic zone;

(ii) it is not formed by the splitting up, or the reconstruction, of a business already in existence:

Provided that this condition shall not apply in respect of any undertaking which is formed as a result of the re-establishment, reconstruction or revival by the assessee of the business of any such undertakings as is referred to in Section 33B, in the circumstances and within the period specified in that section;

(iii) it is not formed by the transfer to a new business of machinery or plant previously used for any purpose.

5.3 Thus, according to the CIT(A), the case of the assessee was covered by the

provisions of section 10A(2)((b) since they got registered on 28.09.1999 and started

business on 13.03.2000 at the Software Technology Park. Trivandrum and had been

in the business of exporting computer software since then. According to the CIT(A)

the Assessing Officer's observation in the remand report dated 17.11.2017 stating

that “the assessee had commenced manufacturing or production on 13.10.2010 as

per Form No.56F submitted but as per section 10A, the assessee can claim

deduction u/s 10A for a period of 10 consecutive assessment years beginning with

the assessment year relevant to the previous year in which the undertaking begins

to manufacture or produce. So, the assessee is eligible for 10A deduction only from

AY 2010-11 and not for AY 2009-10, the year under consideration ", is factually

incorrect since the same was an outcome of typographical error inadvertently

committed by the assessee in Form No.56F filed on 17.02.2016, a copy of which 8

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was forwarded to the Assessing Officer while calling for remand report and no

further action in this regard need be taken as the manufacture or production had

rightly been started only on 13.03.2000 based on which not only the assessment

orders for the earlier assessment years were passed but also the appellate

proceedings were also completed.

5.4 For the alternative claim of deduction made u/s 10A of the Act, the CIT(A)

called for remand report from the incumbent Assessing Officer. The assessing

authority on verification of details furnished by the assessee brought out the

following issues as identified and for further consideration:

“(a) The assesses has commenced manufacturing or production on 13.03.2010 as per form 56F submitted, but as per section 10A the assesses can claim the deduction u/s 10A for a period of 10 consecutive assessment years beginning with the assessment year relevant to the previous year in which the undertaking begins to manufacture or produce. So assessee is eligible for 10A deduction only from AY 2010-11, and not for AY 2009-10.

(b) As per section 80A(5) of the Income Tax Act 1961 deduction u/s 10A can be allowed only if the claim is made in the return of income filed. The assessee has claimed deduction u/s 10A only in the return of income filed against notice u/s 147. Hence assessee is not eligible for claiming deduction u/s IDA of the Act

(c) From the submission of the assessee it was seen that the assessee did not e-file form 56F along with the return of income, however, the assessee has furnished Form 56F on 17.02.2016. However as per the provisions of section 10A, deduction u/s 10A is not admissible if the assessee fails to furnish form 56F aiong with the return of income.

(d) It is also brought to your kind attention that revision u/s 263 was completed on 29.06.2017 in this case and there is a change in total turnover and hence, deduction u/s 10A and hence, the computation submitted by assessee will have to be modified accordingly.

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In view of the points (a) to (c) above, it appears that assessee is not eligible for deduction u/s. 10A.”

5.5 From the above, it could be made out that the first appellate authority had

power to entertain a fresh claim of deduction not been made before the Assessing

Officer. According to the CIT(A), the Assessing Officer had not commented

adversely on the allowability of deduction u/s 10A claimed by the assessee except

pointing out that the deduction can be allowed only if the claim was made in the

original return filed but not in the return which was filed subsequent to the notice

issued u/s 148 of the Act. Further, the CIT(A) observed that provisions regarding

filing of audit report etc. had been declared directory but not mandatory and

thereby, audit report etc. could be filed even during the course of assessment

proceedings and appellate proceedings as well. The CIT(A) relied on the decision

of the ITAT, Cochin Bench in the case of CWP Taylor vs. CIT supra, the decision of

the Supreme Court in the case of Goetze India Ltd. supra is limited to the power of

Assessing Officer only and does not affect the powers of the first appellate authority

in entertaining the claim not been made before the Assessing officer by filing a valid

return.

5.6 The CIT(A) referred to the letter of the representative dated 22.02.2016

explaining how the assessee had fulfilled all the conditions contemplated u/s 10A of

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the Act and satisfied that the assessee is eligible for deduction. The conditions

contemplated u/s 10A were complied with as follows:

Sub-section 1 100% deduction is allowed for a ten (10) Yes consecutive assessment years on profits earned from export of computer software from the year in which the unit begins to manufacture computer software, subject to conditions mentioned in the sub-sections to 10A Sub-section 1A Conditions for deduction under section available Not applicable Sub-section 1B to erstwhile units in SEZ Sub-section 1C Sub-section 2 The unit should begin development of software Yes – In the (i) in a Software Technology park Limited on or year of after 01 April, 1994. (The Company had formation for all obtained approval as a 100% export oriented three eligible unit from STPI on 28 September 1999) units. Sub-section 2(ii) The unit should not be formed by splitting up or reconstruction of a business already in existence. (The eligible unit of the company were newly formed in AY 1999-2000) Sub-section The unit should not be formed by transfer of 2(iii) plant and machinery previously used. Sub-section 3 Sales and proceeds of computer software Yes should be received within a period of 6 months or such other extended time prescribed by Reserve Bank of India. Sub-section 4 The profits eligible for section 10A of the Act, Yes shall be the amount which bears to the profits of the business of the undertaking, the same proportion as the export turnover in respect of such computer software bears to the total turnover of the business carried on by the undertaking. Sub-section 5 For availing benefit under section 10A of the Yes Act, Form 56F should be furnished

Sub-section 6(i) (Applicable only till A.Y. 2000-01 Not applicable Sub-section 6(ii) (Applicable only till AY 2000-01) Not applicable. Sub-section No deduction under section 80HH or 80HHA or Yes 6(iii) section 80-I or setion 80-IA or section 80-IB is allowable on profits of the undertaking Sub-section In computing the depreciation allowance under Yes 6(iv) section 32, the written down value of any asset used for the purposes of the business of the undertaking shall be computed as if the assessee had claimed deduction in respect of depreciation for each of the relevant

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assessment year Sub-section 7 Transfer of goods and services must be at fair Not applicable market value of goods in case of availing deduction under section 10a of the Act Sub-section 7A Tax holiday benefits in case of transfer of Not applicable undertaking pursuant to amalgamation or demerger is subject to certain restrictions.

5.7 In view of the above, the CIT(A) held that the assessee is eligible for

deduction u/s. 10A of the Act and he relied on the judgment of the Delhi High Court

in the case of CIT vs Technovate E Solutions P Ltd reported in 354 ITR 110 wherein

it was held as follows:

" That the Central Board of Direct Taxes in Instruction No.l of 2006, dated March 31, 2006, clarified that the claim of deduction under section 10A should not be denied to the software technology park units only on the ground that the approval / registration to such units had been granted by the Directors of the Software Technology Parks of India. In the instruction, the Board also made a reference to the Inter-Ministerial communication dated March 23, 2006, issued by the Secretary, Ministry of Communications and Technologies to the effect that the approvals issued by the directors of the Software Technology Parks of India had the authority of the Inter-Ministerial Standing Committee and that all approvals granted by the directors of the Software Technology Parks of India were, therefore, deemed to be valid. The position was also clear from a letter dated May 6, 2009, issued by the Board to the Joint Secretary, Ministry of Commerce and Industry wherein a distinction had been drawn between the provisions of sections 10A and 10B and in which it had been clarified that a unit approved by a director under the Software Technology Parks Scheme would be allowed exemption only u/s 10A as a software technology park unit and not u/s 10B as a 100 percent export oriented unit. Therefore, approvals granted by the directors of the Software Technology Parks of India would be deemed to be valid in as much as the directors were functioning under the delegated authority of the Inter-Ministerial Standing Committee. Thus, the Tribunal was right in coming to the conclusion that the approval granted by the directors of the Software Technology Parks of India was sufficient approval so as to satisfy the conditions relating to approvals u/s 10A".

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5.8 The CIT(A) placed reliance on the decision of the ITAT, Cochin Bench, Cochin

passed in the assessee's own case for the AY 2007-08 in ITA No.153/Coch/2015 dt.

26.09.2016 confirming the order of the CIT(A) while allowing the assessee to be

entitled for deduction u/s 10A.

5.9 In the backdrop, considering the fact that the assessee itself had claimed two

different amounts for the deduction to be allowed u/s 10A and the Assessing Officer

also had mentioned in the remand report submitted about change in the turnover

subsequent to the order passed u/s 263, the Assessing Officer was directed to work

out the claim of deduction to be allowed u/s 10A afresh in accordance with the Act.

Accordingly, the CIT(A) allowed the appeal of the assessee.

6 Against this, the Revenue is in appeal before us.

was considered by the Jurisdictional High Court in the case of CIT vs. Flytxt

Technology (P) Ltd. 87 taxmann.com 77 where it was held as follows:

“6. We have considered the submissions made. Admittedly, the assessee initially claimed the benefit of Section 10B which was allowed by the Assessing Officer. Only when the Commissioner was seized of the proceedings under Section 263, the assessee raised an alternative claim for the benefit of Section 10A. The Commissioner did not examine that plea and on the other hand, directed the Assessing Officer to withdraw the exemption under Section 10B. It 13

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was this order which was challenged by the assessees in the appeals filed by them before the Tribunal. Such an appeal filed by the assessee is liable to be considered by the Tribunal exercising its power under Section 254 of the Act which obliged the Tribunal to consider appeal and pass such orders thereon as it thinks fit. It was this power of the Tribunal which considered by the Apex Court in National Thermal Power Co. Ltd.'s case (supra) which held that the Tribunal is only required to consider the questions of law arising from the facts which are on record, there is no reason why such a question should not be allowed to be raised when it is necessary to consider that question in order to correctly assess the tax liability of an assessee. Even if the contention raised by the learned Senior Counsel for the revenue that the power conferred on the appellants under Section 263 only authorised him to examine whether the order passed by the Assessing Officer is erroneous and prejudicial to the interests of the revenue, that restriction of power cannot affect the powers of the Tribunal which is bound to exercise under Section 254 of the Act. In such a situation, having regard to the language of Section 254 and as interpreted by the Apex Court in National Thermal Power Co. Ltd.'s case (supra), we do not see any reason to think that the Tribunal has committed an illegality by directing the Assessing Officer to decide the matter afresh duly adverting to the claim of the assessee for the benefit of Section 10A.

In the aforesaid circumstances, we do not find any illegality in the order passed by the Tribunal. Therefore, the questions of law framed have to be answered in favour of the assessee and against revenue. Accordingly, the appeals are dismissed.”

8.1 In view of the above judgment of the Jurisdictional High Court in the case of

CIT vs. Flytxt Technology (P) Ltd. supra, the second ground of appeal of the

Revenue is dismissed.

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u/s. 10A of the Act by the CIT(A), in our opinion, there is no bar to entertain such

claim by the CIT(A) otherwise than by filing a revised return as held by the Supreme

Court of India in the case of Goetze (India) Ltd. (284 ITR 323). Being so, Ground

No. 3 of the Revenue is dismissed.

Jurisdictional High Court in assessee’s own case for the assessment year 2007-08, Q

Burst Technologies Pvt. Ltd. for AYs 2008-09 and 2010-11 and Paragon Biomedical

India Pvt. Ltd. for AYs 2010-11 and 2011-12 which is pending before the

Jurisdictional High Court on similar issue.

10.1 Since we have followed the decision of the Jurisdictional High Court in the

case of CIT vs. Flytxt Technology (P) Ltd. 87 taxmann.com 77, there is no question

of awaiting for further decision of the Jurisdictional High Court on this issue.

Accordingly, the fourth ground of appeal of the Revenue is dismissed.

the Assessing Officer had noticed that the assesses had given interest free advances

to its associate concerns namely Toons Animation India (,P) Ltd and UST Global

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Information Technology Parks (P) Ltd without charging interest thereon. The

Assessing Officer further noticed that the assessee had availed interest bearing

loans to the tune of Rs.60.51 cr and paid interest of Rs.7.40 cr thereon during the

year under consideration. He took the view that the assessee had diverted interest

bearing funds to its associate concerns for non business purposes that too without

charging interest. The assessee objected to the inference drawn by the assessing

authority and also submitted that it is eligible for deduction u/s 10B of the Act.

However, the Assessing Officer by placing reliance on the decision of the

jurisdictional High Court of Kerala in the case of CIT vs. V I Baby & Co (254 ITR

248) disallowed proportionate amount of interest relatable to the amounts diverted

to the associate concerns. The disallowance worked out is Rs.1,18,408/-.

case for the AY 2008-09 in ITA No.02/Coch/2013 dt.23.08.2013, the ITAT, Cochin

Bench had decided the issue in favour of the assessee and deleted the interest

which was proportionately disallowed. Since the issue involved for the year under

consideration is also same and identical to each other, respectfully following the

said decision of the ITAT, the CIT(A) deleted the interest of Rs.1,18,408/-

proportionately disallowed and accordingly, the appeal filed on this ground was

allowed.

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similar issue was considered by this Tribunal in assessee’s own case in IT(TP)A

No.02/Coch/2013 dated 23/08/2018, wherein it was held as follows:

“6. We have heard the rival contention and carefully perused the record. From the assessment order, we notice that the AO has disallowed a part of interest expenditure claim on the reasoning that

(a) that assessee has given interest free advances to sister concerns as per the Balance Sheet as at 31.3.2008 and

(b) the decision rendered by Jurisdictional Hon'ble Kerala High Court in the case of V.I. Baby (supra) supports disallowance of interest attributable to the funds diverted. In the written submissions, the assessee has tabulated the year wise details of funds given to the sister concerns as well as the reserves and surplus funds available with it in those years. For the sake of convenience, we extract below the said details:

Financial Amt disbursed Amt disbursed to Total advances Reserves and Year to TeN Toonz surplus

2002-03 2,551,812 - 2,551,812 51,459,144

2003-04 5,959,312 - 5,959,312 93,539,478

2004-05 961,388 - 961,388 139,593,897

2005-06 325,049 - 325,049 209,274,643

2006-07 - 700,000 700,000 467,452,244

2007-08 - - - 717,455,603

Total 9,797,561 700,000 10,497,561

Thus, it is seen that the assessee has advanced the amounts to its sister concerns in the earlier years and not during the year under consideration, as presumed by the

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assessing officer. Thus, the presumption entertained by the AO is against the facts available on record.

16.1 Further, we rely on the judgment of the Bombay High Court in the case of

CIT vs. Gem Plus Jewellery India Ltd. 330 ITR 177 wherein it was held as follows:

“iv) That it was an admitted position that the assessee had deposited both the employer’s and the employees’ contribution towards provident fund and ESIC, though beyond the due date including the grace period. the Assessing Officer added these payments to the total income of the assessee. The disallowance which was effected by the Assessing Officer had not been challenged by the assessee. The plain consequence of the disallowance and the add back that had been made by the Assessing Officer was an increase in the business profits of the assessee. The contention of the Revenue that in computing the deduction under section 10A, the addition made on account of the disallowance of the provident fund/ESIC payments ought to be ignored 18

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could not be accepted. No statutory provisions to that effect having been made, the plain consequence of the disallowance made by the Assessing Officer must follow. The Tribunal was justified in directing the Assessing Officer to grant the exemption under section 10A of the Act on the assessed income, which was enhanced due to disallowance of the employer’s as well as employees’ contribution towards PF/ESIC.”

16.2 In view of this, we are of the opinion, that even if disallowance is made

towards notional interest on account of diversion of funds to the sister concerns, it

is of no consequence since the assessee’s income is exempted u/s. 10A of the I.T.

Act.

16.3 Thus, in view of the above order of the Tribunal in assessee’s own case in

ITA No. 02/Coch/2013 dated 23/08/2013 and the judgment of the Bombay High

Court in the case of CIT vs. Gem Plus Jewellery India Ltd. (supra), we are inclined

to dismiss the fifth ground of appeal of the Revenue.

assessee are dismissed. Order pronounced in the open court on 4th December, 2019.

sd/- sd/- (GEORGE GEORGE K.) (CHANDRA POOJARI) JUDICIAL MEMBER ACCOUNTANT MEMBER

Place: Kochi Dated: 4th December, 2019 GJ Copy to: 19

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(ASSISTANT REGISTRAR) I.T.A.T., Cochin