DIOSMA LIFESCIENCES PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER WARD 4(1) THANE, THANE
IN THE INCOME-TAX APPELLATE TRIBUNAL“SMC” BENCH,
MUMBAI
BEFORE Ms. KAVITHA RAJAGOPAL, JUDICIAL MEMBER
&
SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER
Diosma Lifesciences Private
Limited
Shop
No.
77,
C-Wing,
Harmony
Mall
Commercial
Premises, Bhagat Singh Nagar
No.1,
Link
Road,
Goregaon(West),
Mumbai
-
400 104, Maharashtra v/s.
बनाम
Income Tax Officer, Ward –
4(1),
Qureshi
Mansion,
Gokhale
Road,
Naupada,
Thane West, Thane - 400
602, Maharashtra
स्थायी लेखा सं./जीआइआर सं./PAN/GIR No: AAFCD0525R
Appellant/अपीलार्थी
..
Respondent/प्रतिवादी
Appellant by :
Shri Vipul Shah, AR
Respondent by :
Shri Aadesh Rai, Addl. CIT, (Virtually appeared)
Date of Hearing
05.08.2025
Date of Pronouncement
16.09.2025
आदेश / O R D E R
PER PRABHASH SHANKAR [A.M.] :-
The present appeal arising from the appellate order is filed by the assessee against the order passed by the Learned Commissioner of Income-tax(Appeals)/National
Faceless
Appeal
Centre,
Delhi
[hereinafter referred to as “CIT(A)”] pertaining to assessment order passed u/s. 143(3) of the Income-tax Act, 1961 [hereinafter referred to as “Act”] dated 24.02.2021 for the Assessment Year [A.Y.] 2018-19. P a g e | 2
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Diosma Lifesciences Private Limited
The grounds of appeal are as under: Legal & Procedural Grounds: Invalidity of Assessment due to Non-Service of Notice u/s 143(2): 1. On the facts and circumstances of the case and in law the Ld. CIT(A) erred in upholding the assessment order, which is void ab initio, as the mandatory notice under section 143(2) of the Act, dated 28/09/2019, was never served upon the Appellant through its registered email ID.The Ld. CIT(A) also failed to adjudicate the specific ground raised by the Appellant that it had not received any communication from the A.O. Violation of Principles of Natural Justice: 2. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in holding that adequate opportunity was provided to the Appellant without appreciating the fact that the assessment was completed during the peak of the COVID-19 pandemic under the newly introduced faceless assessment scheme, and the alleged non- compliance stemmed from a lack of proper communication due to non- receipt of notices. 3. On the facts and circumstances of the case and in law the CIT(A) erred in upholding action of the Assessing Officer in completing assessment on presumptions and assumptions without appreciating a fact that out of the 15 individuals to whom notices under section 133(6) were purportedly sent, 3 had incorrect/no PAN details and 7 persons never received the notices, which wasbeyond the control of the Appellant. Holding the Appellant responsible for non-compliance by third parties, is unjust. Factual Grounds on Merits of the Case: On Erroneous Disallowance of Sales Promotion Expenses u/s. 37(1):
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Diosma Lifesciences Private Limited
On the facts and in the circumstances of the case, the Ld. CIT(A) erred in confirming the disallowance of Rs. 30,62,507/-incurred wholly and exclusively for the purpose of the Appellant's business, without appreciating the nature of the expenses, which were reimbursements for travelling, local conveyance, accommodation, and food incurred by the Appellant's marketing staff/employees for meeting medical professionals to promote its products and not “freebies” to doctors. 5. On the facts and circumstances of the case and in law, the learned CIT(A) erred in confirming the action of the Assessing Officer in placing reliance on the CBDT Circular No. 5/2012 and Indian Medical Council Regulations, which are not applicable to the Appellant. On Ignoring Commercial Expediency: 6. On the facts and circumstances of the case and in law the Ld. CIT(A) failed to appreciate the commercial expediency of the expenditure and confirming the disallowance of the entire expenditure on the basis of a comparison with previous years, without appreciating the business context of a new and growing company, is arbitrary and against the principles of business prudence. The Appellant prays that the disallowance made be deleted. On Disallowance of Entire Expenditure without basis: 7. Without prejudice to above grounds, On the facts and circumstances of the case and in law the complete disallowance of Rs. 30,62,507/- is highly excessive and punitive. The learned CIT(A) failed to appreciate that the A.O. failed to examine the submitted ledgers and made a blanket disallowance without pointing out a single specific instance of an inadmissible expense. The Appellant prays that disallowing entire expenditure is against the fundamental principles of taxation and the disallowance made be deleted.
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Diosma Lifesciences Private Limited
In ground nos.1 and 2, the assessee has claimed that the mandatory notice under section 143(2) of the Act was never served upon it through its registered email ID. The ld. CIT(A) also failed to adjudicate the specific ground raised that it had not received any communication from the A.O. Besides, the ld. CIT(A) in violation of principle of natural justice erred in holding that adequate opportunity was provided to the assessee without appreciating the fact that the assessment was completed during the peak of the COVID-19 pandemic under the newly introduced Faceless assessment scheme and the alleged non-compliance stemmed from a lack of proper communication due to non-receipt of notices. 3.1 We have gone through the records and find that prima facie the contentions of the assessee are self-contradictory and factually incorrect. Moreover, at no point, be it assessment or appellate proceedings, the assessee has raised the ground regarding non service of notice u/s 143(2) of the Act as apparent from the assessment as also the appellate order. In fact, the assessee even in the Statement of Facts submitted before the ld.CIT(A) has categorically admitted issue of impugned notice to it by the AO. Likewise, the ground on lack of adequate opportunity of hearing is also not supported from its own contentions as per SOF relevant part of which are reproduced as below:
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Diosma Lifesciences Private Limited
“Your appellant M/s. Diosma Lifesciences Private Limited is a closely held company having its registered office at Shop No. 10, Galaxy III Co. Op. Hsg. Soc. Ltd., Om
Nagar, Ambadi Road, Dhuri Complex, Vasai Road (West) – 401 202. The return of income for the assessment year 2018-19 was filed on 09/10/2018 declaring total income of Rs.6,96,960/-. The scrutiny assessment under section 143(2) read with Section 143(3A) and 143 (3B) of the Income Tax Act, 1961 was initiated vide notice dated 28.09.2019 and notices under section 142(1) of the Income Tax Act were issued dated 17.12.2019, 28.07.2020, 11.09.2020 and 27.01.2021 and the replies were submitted on 06.08.2020, 15.10.2020 and 29.01.2021. Show Cause Notice u/s 143(3) issued on 11.02.2021 and reply was submitted on 15.02.2021. In this case, order u/s 143(3) read with sections 143(3A) & 143(3B) of the Income-tax Act was passed on 06.12.2019 by the assessing officer stating that the business/ sales promotion expenses of Rs. 30,62,507/- is to be disallowed without considering the facts and considering the same as not genuine.”
2 Therefore, it has been admitted that the assessee was not only issued various notices u/s 143(2)/142(1) of the Act from time to time, it attended to the same and replies were submitted on several occasions. There is absolutely no basis for claiming that notices were not served on it and was denied adequate opportunity of hearing. Even during appellate proceedings, perusal of the appellate order makes it evidently clear that the ld.CIT(A) allowed adequate opportunity of hearing to it as evident from page 5 to 8 of the appellate order wherein the ld.CIT(A) has reproduced the written submissions made by the assessee before him. “Even the assessment order in para 3 refers to statutory notice u/s 143(2) was issued and served on the assessee on 28.09.2019 which was not complied with. Thereafter, notice u/s 142(1) of the Act was issued on 17.12.2019 which was also not complied with. Thereafter, notice u/s P a g e | 6 A.Y. 2018-19
Diosma Lifesciences Private Limited
142(1) of the Act was issued on 28.07.2020 which was complied with by the assessee company.” In the light of above facts, we do not find any merit in the contentions of the assessee. Consequently, both the ground nos.1 and 2 are dismissed.
4. In ground nos. 3 to 7 the assessee has contested the disallowance of Rs. 30,62,507/- debited under head Sales promotion including publicity (other than advertisement).Briefly stated, it was noticed by the AO that the assessee had debited the above sum as Sales promotion expenses. Before him, it was contented that the assessee is a manufacturer of pharmaceutical formulations and marketing expenses were major expenses of the industry. Apart from salaries, it had to make payment for daily of marketing staff like travelling accommodation and food etc. every month. The expenses were reimbursed to the marketing staff on the basis of their statement of expenses. After taking relevant detail of such expenses and the list of 15 persons to whom payment with regard to Sales Promotion were made, the AO examined and it was noticed that some of person left the organisation and PAN details and other details were not submitted. So, it was very difficult to ascertain with from the bank statements about nature of such payment as to whether the same were for their salary or other re-imbursement as the assessee had already debited salary expense separately. Such persons to P a g e | 7
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Diosma Lifesciences Private Limited whom notice u/s 133(6) of the Act were issued were asked to verify whether the company had made any payment other than salary which was being claimed by the assessee under head ‘sales promotion’. No response from any of the persons was received by the AO. It was submitted by the assessee that there was a substantial increase of Rs.38,06,126/- in the turnover of the company in the AY 2018-19 as compared to the turnover in the AY 2017-18 and the management of the company could foresee an increase in the subsequent years as well. The sales promotion expense incurred was to create a base for the company in the future years and promote business expansion.
4.1 However, subsequently, the assessee changed its stand submitting that these expenses debited under head ‘sales promotion’
amounting to Rs. 30,62,507/- were amounts / gifts given to Doctors. In justification of allowablity of the same, the assessee company cited case laws of M/s Aishika Pharma Pvt Ltd Vs The ITO (ITAT Delhi) (Appeal
No. ITA No. 732/Del/2019 dt 29.04.2019).
5. The AO observed that as per CBDT vide Circular No. 5/
2012 dated 01.08.2012 expenses incurred on freebies to doctors are inadmissible under section 37(1) of the Act. Circular No. 5/2012 dt
01.08.2012 is reproduced below:
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Diosma Lifesciences Private Limited
“INADMISSIBILITY OF EXPENSES INCURRED IN PROVIDING
FREEBEES TO MEDICAL PRACTITIONER BY PHARMACEUTICAL
AND ALLIED HEALTH SECTOR INDUSTRY CIRCULAR NO. 5/2012
[F. NO. 225/142/2012-ITA.II], DATED 1-8-2012:
It has been brought to the notice of the Board that some pharmaceutical and allied health sector Industries are providing freebees (freebies) to medical practitioners and their professional associations in violation of the regulations issued by Medical Council of India (the 'Council') which is a regulatory body constituted under the Medical Council Act, 1956. 2. The council in exercise of its statutory powers amended the Indian Medical
Council (Professional Conduct, Etiquette and Ethics) Regulations, 2002 (the regulations) on 10-12-2009 imposing a prohibition on the medical practitioner and their professional associations from taking any Gift, Travel facility, Hospitality,
Cash or monetary grant from the pharmaceutical and allied health sector
Industries.
3. Section 37(1) of Income Tax Act provides for deduction of any revenue expenditure (other than those failing under sections 30 to 36) from the business
Income if such expense is laid out/expended wholly or exclusively for the purpose of business or profession. However, the explanation appended to this subsection denies claim of any such expense, if the same has been incurred for a purpose which is either an offence or prohibited by law. Thus, the claim of any expense incurred in providing above mentioned or similar freebees in violation of the provisions of Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations,
2002 shall be inadmissible under section 37(1) of the Income Tax Act being an expense prohibited by the law. This disallowance shall be made in the hands of such pharmaceutical or allied health sector Industries or other assessee which has provided aforesaid freebees and claimed it as a deductable expense in its accounts against income.
4. It is also clarified that the sum equivalent to value of freebees enjoyed by the aforesaid medical practitioner or professional associations is also taxable as business income or income from other sources as the case may be depending on the facts of each case. The Assessing Officers of such medical practitioner or professional associations should examine the same and take an appropriate action.
This may be brought to the notice of all the officers of the charge for necessary action. “
5.1 It was also stated even Indian Medical Association (IMA) has imposed prohibition on acceptance of gift, travel facility, hospitality,
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Diosma Lifesciences Private Limited cash or monetary grant from the pharmaceutical and allied health sector industries. Section 37(1) of the Act provides deduction of any revenue expenditure (other than those falling under sections 30 to 36) from the business income if such expense is laid out / expended wholly or exclusively for the purposes of business or profession. However, explanation appended to this sub-section denies claim of any such expense, if the same has been incurred for a purpose which is either an offence or prohibited by law
5.2 In view of above facts, the AO concluded that genuineness of claim of expenses could not be established though the onus was on the assessee to prove the same and establish that expenses were laid out or expended wholly and exclusively for the purpose of the business as per the provisions of section u/s 37(1) of the Act. However, assessee could not prove its claim during the assessment proceedings and kept on changing its version. Thus, he concluded that the nature of the expenditure under head “Sales Promotion” amounting to Rs.
30,62,507/- was not proved by the assessee and even the names of the recipients of such expenses were not disclosed. Accordingly, claim was disallowed for deduction u/s 37(1) of the Act holding that the same was not genuine and added back to the income of the assessee.
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Diosma Lifesciences Private Limited
In the subsequent appeal, the ld.CIT(A) observed that initially the appellant had claimed that the said expenses were incurred on some employees whose list was provided to the AO by it. However, during the assessment proceedings, it changed its justification with regard to claim of sales promotion and stated that these expenses the amount debited under head 'sales promotion' amounting to Rs.30,62,507/- were amounts/gifts/freebies given to doctors. The appellant had stated that they had provided gifts to doctors’ staff during Diwali festival but the gifts were not those as prohibited by section 37 and were based purely on the grounds of humanity and relations and as token of gratitude. The ld.CIT(A) observed that the appellant has itself had accepted that it had provided gifts to the doctors/staff and for the same it had debited Rs.30,62,507/- under head Sales promotion including publicity (other than advertisement) which was quite high. The appellant is in the business of medical profession and has to follow rules and regulations that are necessary for ethical medical profession. The appellant has given the list of 15 persons to whom it has made the payments as reimbursement of expenses. Even during the assessment proceedings, the appellant failed to provide such details. Moreover, giving gifts to doctors/staff is considered an unethical/illegal business practice in business profession. According to him, the CBDT has clear cut
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Diosma Lifesciences Private Limited guidelines that the expenses incurred on freebies to doctors are inadmissible under Section 37(1) of the Income Tax Act, 1961. The AO has also referred to this CBDT Circular No. 5/2012 dated
01.08.2012.The Explanation 1 to the section 37 clearly states that any expenditure incurred by an assessee for any purpose which is an offence or which is prohibited by law shall not be deemed to have been incurred for the purpose of business or profession and no deduction or allowance shall be made in respect of such expenditure. Considering the above facts, the ld.CIT(A) upheld the disallowance dismissing the appeal of the assessee in this regard.
In the course of hearing before us, the ld.AR has contested the conclusion drawn by the authorities below on the ground that case of the assessee was not hit by the provisions of Explanation 1 to section 37(1) of the Act in as much the expenditure incurred could not be considered as prohibited by CBDT Circular and MCI Guidelines. Pre contra, the ld.DR placed reliance on the order of the lower authorities and the provisions of the Act in this respect.
We have carefully considered the above facts and find palpable contradiction in the stand of the assessee before the lower authorities. It kept changing its stand which was initially claimed to be payment to P a g e | 12 A.Y. 2018-19
Diosma Lifesciences Private Limited employees which was later changed to freebies paid to medical professionals on the occasion of Diwali.The AO, in this backdrop, took note of the content of the CBDT circular No. 05/2012 dated 1st August
2012, the amendment in the Medical Council of India regulations vide
Gazette notification dated 10thDecember, 2009, and Explanation Section 37(1) of the Act.
9. It is now settled law that the Board vide Circular No. 05/2012
(F.No. 225/142/2012-ITA.II), dated 01.08.2012 stated that Indian
Medical
Council
(Professional
Conduct,
Etiquette and Ethics)
Regulations, 2002, on 10.12.2009 imposed a prohibition on medical practitioners and their professional associations from taking any Gift,
Travel facility, Hospitality, Cash or monetary grant from pharmaceutical and allied health sector industries. Section 37(1) of the Act provides for deduction of any revenue expenditure (other than those failing under section 30 to 36) from business income if such expense is laid out/expended wholly or exclusively for the purpose of business or profession. However, the explanation appended to this sub-section denies claim of any such expense, if the same has been incurred for a purpose which is either an offence or prohibited by law. Thus, the claim of any expense incurred in providing freebies in violation of the P a g e | 13
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Diosma Lifesciences Private Limited provisions of IMC (Professional Conduct, Etiquette and Ethics)
Regulations, 2002 shall not be admissible under section 37(1) of the Act being an expense prohibited by the law. Once this has been prohibited by the Medical Council under the powers vested in it, section 37(1) of the Act comes in to play.
9.1 Further, the Explanation inserted to the section 37(1) by the Finance Act (No.2), 1998 is with retrospective effect from 01.04.1962. Therefore, the expense of the nature specifically mentioned to be not allowable in the captioned circular of CBDT would have its applicability in respect of the cases of the earlier period years as well.
The Explanation to section 37(1) is on the statute w.e.f. 1st April, 1962. The same has simply been clarified by way of a circular issued by CBDT.
The MCI in exercise of powers conferred under section 20A read with section 33(m) of the Indian Medical Council Act, 1956 (MC) has framed The Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations 2002, which describes unethical acts under Chapter 6 of the said regulations. The MCI has made amendment in the above regulation vide notification dated 10-12-2009. As per said notification, a medical practitioner is not allowed to receive any gift, travel facility, hospitality, cash or monetary grants from the P a g e | 14
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Diosma Lifesciences Private Limited pharmaceuticals or allied health care industry and violation of these conducts are liable for punishment as per The Indian Medical Council
(Professional Conduct, Etiquette and Ethics) Regulations, 2002. 9.2 At this stage, it is relevant to refer to the judgment of the Hon’ble Apex Court in the case of Apex Laboratories Pvt Ltd
(2022) 442 ITR 1 (SC) wherein it considered the issue as to why the expenditure incurred towards gifting freebies to medical practitioners for creating awareness about the health supplement ‘Zincovit’, should not be added back to the total income of the said Company. The Apex
Court dealt with the issue and held thus:
” 27. It is also a settled principle of law that no court will lend its aid to a party that roots its cause of action in an immoral or illegal act (ex dolomalo non oritur action) meaning that none should be allowed to profit from any wrongdoing coupled with the fact that statutory regimes should be coherent and not self- defeating. Doctors and pharmacists being complementary and supplementary to each other in the medical profession, a comprehensive view must be adopted to regulate their conduct in view of the contemporary statutory regimes and regulations. Therefore, denial of the tax benefit cannot be construed as penalizing the assessee pharmaceutical company. Only its participation in what is plainly an action prohibited by law, precludes the assessee from claiming it as a deductible expenditure.
28. This Court also notices that medical practitioners have a quasi-fiduciary relationship with their patients. A doctor’s prescription is considered the final word on the medication to be availed by the patient, even if the cost of such medication is unaffordable or barely within the economic reach of the patient – such is the level of trust reposed in doctors. Therefore, it is a matter of great public importance and concern, when it is demonstrated that a doctor’s prescription can be manipulated, and driven by the motive to avail the freebies offered to them by pharmaceutical companies, ranging from gifts such as gold coins, fridges and LCD TVs to funding international trips for vacations or to attend medical conferences. These freebies are P a g e | 15
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Diosma Lifesciences Private Limited technically not ‘free’ – the cost of supplying such freebies is usually factored into the drug, driving prices up, thus creating a perpetual publicly injurious cycle….”
9.3 While the Apex Court approved the dictum of the Punjab &
Haryana High Court in Commissioner of Income-Tax v. Kap Scan and Diagnostic Centre P. Ltd.(2012) 344 ITR 476 (P&H HC) and Himachal Pradesh High Court in Confederation of Indian
Pharmaceutical Industry (SSI) v. Central Board of Direct Taxes
(2013) 353 ITR 388 (HP HC), it distinguished/overruled a number of earlier judgments of the High Courts, which ran contra to the dictum of Apex Laboratories (supra). In Commissioner of Income-Tax v. Kap
Scan and Diagnostic Centre P. Ltd.(supra), the hon’ble Punjab &
Haryana High Court held payment of commission to doctors as against public policy and held thus:
“18. If demanding of such commission was bad, paying it was equally bad. Both were privies to a wrong. Therefore, such commission paid to private doctors was opposed to public policy and should be discouraged. The payment of commission by the assessee for referring patients to it cannot by any stretch of imagination be accepted to be legal or as per public policy. Undoubtedly, it is not a fair practice and has to be termed as against the public policy.
19. Further, section 23 of the Contract Act equates an agreement or contract opposed to public policy, with an agreement or contract forbidden by law. section 23 of the Contract
Act reads thus:
“23. What consideration and objects are lawful, and what not. —The consideration or object of an agreement is lawful, unless— it is forbidden by law; or is of such a nature that, if permitted, it would defeat the provisions of any law; or is fraudulent; or involves or implies, injury to the person or property of another; or the court regards it as immoral, or opposed to public policy. In each of these cases, the consideration or object of an agreement is said to be unlawful. Every agreement of which the object or consideration is unlawful is void. ….. 23. 9.4 In the case of Confederation of Indian Pharmaceutical
Industry (SSI) v. Central Board of Direct Taxes held that the P a g e | 16
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Diosma Lifesciences Private Limited impugned is in consonance with section 37(1) of the Act. It is relevant to refer to Gwalior Road Lines v. CIT, [1998] 234 ITR 230 (MP) wherein the hon’ble Court dealt with the amount illegally paid to the police authorities for running their business. The Court categorically held that after insertion of the Explanation to section 37(1) by the Finance Act,
1998, with effect from April 1, 1962, the assessee could not claim such payment as expended for commercial exigency and, therefore, the same was not an allowable deduction. Similarly, the hon’ble Allahabad High
Court in Pt. Vishwanath Sharma’s case, [2009] 316 ITR 419 (All) while considering the issue relating to commission paid to Government doctors for prescribing assessee’s medicines to patients, held it to be contravening public policy and was therefore an inadmissible expenditure. It would be worthwhile to refer to a recent judgment in the case of Peerless Hospitex Hospital & Research Centre Pvt Ltd Vs
PCIT (2022) 137 taxmann.com 359 (Cal) wherein the hon’ble Calcutta
High Court dealt specifically dealt with similar disallowance of referral fee paid to doctors ‟for referring patients for treatment in its hospital as business expenditure under section 37 (1) of the Income Tax Act, 1961”
in favour of the Revenue.
9.5 It would be appropriate to refer to hon’ble Apex Court case in Maddi Venkataraman & Co. (P) Ltd vs. CIT (1998) 229 ITR 534 (SC)
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Diosma Lifesciences Private Limited wherein it was held that it would be against public policy to allow the benefit of deduction under one statute, of any expenditure incurred in violation of the provisions of another statute or any penalty imposed under another statute.
10. In the light of above discussion, the provisions of the Act and the legal ramifications of the cited decisions as above, we do not find any merit in the above grounds of appeal which are accordingly, dismissed.
11. In the result, the appeal of the assessee is dismissed.
Order pronounced in the open court on 16.09.2025. KAVITHA RAJAGOPAL
PRABHASH SHANKAR
(न्याययक सदस्य /JUDICIAL MEMBER)
(लेखाकार सदस्य/ACCOUNTANT MEMBER)
Place: म ुंबई/Mumbai
ददनाुंक /Date 16.09.2025
Lubhna Shaikh / Steno
आदेश की प्रयियलयि अग्रेयिि/Copy of the Order forwarded to :
1. अपीलार्थी / The Appellant
2. प्रत्यर्थी / The Respondent.
3. आयकर आयुक्त / CIT
4. विभागीय प्रविविवि, आयकर अपीलीय अविकरण DR, ITAT,
Mumbai
5. गार्ड फाईल / Guard file.
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सत्यावपि प्रवि ////
आदेशानुसार/ BY ORDER,
उि/सहायक िंजीकार (Dy./Asstt.