THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1),, GUNTUR vs. DANDU BRAHMANANDAM, CHENNAI

आदेश /O R D E R

Per Shri D.S.Sunder Singh, Accountant Member :

These appeals are filed by the revenue against the order of the Commissioner of Income Tax (Appeals)-1, Guntur vide AppealNo.103/2016-17and No.109/2016-17 dated 22.10.2018 for the Assessment Year (A.Y.) 2014-15. Since the grounds raised in these appeals are common, these appeals are clubbed, heard together and a common order is being passed for the sake of convenience as under.

I.T.A. No.11/Viz/2019, A.Y.2014-15 2. The assessee is an individual, deriving income from salary, advisory fees, house property, capital gains and income from other sources filed his return of income admitting total income of Rs.168,83,71,070/- on 27.09.2014. The case was selected for scrutiny and during the course of assessment proceedings, the Assessing Officer (AO) found that the assessee was a major stake holder, holding 10.34% of shares in M/s Tirumala Milk Products Pvt. Ltd. (M/s TMPPL) and is also a Promoter-Director. During the year, the assessee along with all other individual shareholders and a foreign company entered into an agreement dated 04.11.2013 for sale of

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his total shares in M/s TMPPL to M/s BSA International. In the process, M/s TMPPL has given Engagement Letter (EL) dated 05.07.2013 to M/s Barclays Bank PLC (in short ‘Barclays’) for evaluating the value of its shares, searching a probably buyer to have control over its investments or in its affairs and receipt of sale consideration etc.. The terms of the agreement entered into are that the Barclays Bank has to evaluate the shares, to assist the assessee in identifying the potential buyer and act as a sole financial adviser of the company. On finalization of the transaction the company M/s TMPPL has to pay success fee to M/s Barclays Bank as per the invoice raised. Accordingly, at the end of the transaction, M/s Barclays raised an invoice of Rs.28,81,31,631/- as success fee for the transaction and the same was met by M/s TMPPL. The AO objected for the payment of success fee of Rs.28.81 crores by the company M/s TMPPL for sale of shares of individual stakeholders of the company. The AO is of the view that the payment of success fee was the obligation of the share holders. From the financials of M/s TMPPL, the AO observed that the amount of Rs.28.81 crores, inter-alia was shown as payment down the line of profits. To elaborate M/s TMPPL in the audited financials for the A.Y. 2014-15 arrived at profit of Rs.58,55,28,292/- and down the line, shown the amount

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of Rs.28,81,31,631/- as paid towards professional fee under exceptional items. From the profit and loss account, the AO found that the company has not claimed this amount as expenditure in it’s hands. The AO further observed that the expenditure towards sale of shares was made by the company out of its taxed profits. The AO further opined that the sum of Rs.28.81 crores paid by M/s TMPPL to M/s Barclays Bank required to be considered in the hands of the assessee proportionately u/s 2(24)(iv) of the Income Tax Act. Accordingly, the AO issued show cause letter calling for the explanation of the assessee as to why the amount should not be treated as income in the hands of the assessee. In response, the assessee filed reply stating that the intention behind the transaction was to sell the business of the company fully or partly to a probable buyer and it was not for sale of shares by individuals or proposal to sell the shares of the assessee to M/s BSA International Ltd. The company, M/s TMPPL is responsible for payment of fee upon success of the EL. It is the obligation of the company to pay to M/s Barclays for evaluating it’s assets as on particular date like any other liability and the payment of fee to Barclays was shown as liability for the company while arriving at the value of the shares of the company. The assessee further submitted that he is not the Director at the time of

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raising invoice by M/s Barclays Bank and also as on the date of payment and argued that the provisions of section 2(24) (iv) cannot be invoked in his case. Alternatively, the assessee submitted that in case the payment made to M/s Barclays Bank is to be treated as income in the hands of the assessee, the same is to be allowed as expenditure for transfer of shares u/s 48(1) of the Act. The AO considered the objections and found that the submissions made by the assessee are not in line with the treatment given by M/s TMPPL in its books of accounts. The said amount was not debited to expenditure account but was shown as down the line of adjustments. The actual EL with M/s Barclays was dated 05.07.2013 and the parties to this transaction were M/s Tirumala Milk Products (P) Ltd., and M/s Barclays Bank PLC. It was mentioned in the EL that M/s Barclays was engaged by M/s TMPPL to provide financial advice and related assistance in connection with a possible transaction. The AO observed that the factual development pursuant to the EL that had taken place was that the control over M/s TMPPL has been shifted from the individual shareholders to M/s BSA International Ltd., by of sale of shares held by various stake holders of M/s TMPPL. The assessee being one of the promote-director holding 10.34% of the stake in M/s TMPPL, sold his shares pursuant to the EL and

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received the sale consideration, the benefit of whole transaction of entering into agreement, getting the value of shares evaluated, transfer of shares of individual shares to M/s BSA was certainly derived by the individual share holders, including the assessee and not the company. It is for this reason, the AO viewed that the company has not claimed any expenditure out of the transaction and rightly shown the same as paid out of the taxed profits, below the line of adjustment. The AO also observed that no assets of the company were sold by settlement, but only shareholding of the company was shifted from 41 individual stake holders and one foreign entity to one M/s BSA International Ltd, therefore, viewed the said agreement as a customary exercise and no importance can be attached at any stretch and accordingly held that the proportionate amount of payment made by the company is to be treated as income in the hands of the assessee u/s 2(24)(iv) of the Act.

2.1. The assessee’s alternate argument that he was not the director as on the date of transaction or at the time of raising invoice by M/s Barclays was also not found favour by the AO. The AO observed that though the assessee was not director at the time of raising the invoice, he was the Director as on the date of entering the agreement and held that he certainly derived the

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benefit and the same required to be brought to tax under section 2(24)(iv) of the Act and accordingly, the proportionate amount of Rs.2,97,92,811 paid by M/s TMPPL on sale of shares of the assessee was treated as his income and assessed under the head ‘Other Sources’.

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the Ld.CIT(A) held that the AO’s finding that the certain benefit accrued to the assessee with reference to the success fee paid by M/s TMPPL is incorrect. The Ld.CIT(A) also did not accept the contention of AO that the assessee was the Director at the time of raising the invoice, and held that section 2(24)(iv) is inapplicable in the assessee’s case. The Ld.CIT(A) viewed that the payment was made after the assessee was ceased to be Director and shareholder in the company and the view point of the AO on the issue was also incorrect. Accordingly, allowed the appeal of the assessee.

4.1. During the appeal hearing, the Ld.DR argued that the assessee company M/s TMPPL has paid the sum of Rs.28.81 crores to M/s Barclays Bank. The assessee being the Director and shareholder of 10.34%, the assessee got indirect benefit which required to be taxed u/s 2(24)(iv) of the Act. The Ld.DR further submitted that though the assessee claimed that he was not the Director as on the date of raising the invoice, it is a fact that

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as on the date of entering the agreement, the assessee was Director, hence section 2(24)(iv) attracts in assessee’s case. Though the agreement was entered into between M/s TMPPL and M/s Barclays Bank, no asset was transferred and it was only the shares of the individual shareholders which were transferred, therefore, the contention of the assessee that the agreement entered to provide financial assistance and relative assistance in connection with possible transaction is nothing but a make believe arrangement and the assessee got direct benefit by way of transfer of shares. Therefore, argued that the AO rightly made the benefit derived by the assessee indirectly u/s 2(24)(iv) of the Act. Even the company did not debit the expenditure in its books of accounts and the company also shown the payment down below the taxed profits and reduced from the taxed profits which establishes that the said expenditure was met on behalf of the shareholders. The Ld.DR further argued that the contention of the Ld.CIT(A) is not acceptable with regard to his observation that the assessee was not a Director at the time of raising the invoice, since, he was one of the directors at the time of entering into agreement, he argued that the provisions of section 2(24)(iv) required to be applied in the case of the assessee and the benefit derived by the assessee to be brought to tax.

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Accordingly, the Ld.DR submitted that the AO has rightly reduced the proportionate amount paid to M/s Barclays bank from the long term capital gains and taxed the same as income from other sources. Hence, argued that the Ld.CIT(A) is incorrect in holding that the assessee did not derive any benefit as per the agreement entered into by M/s TMPPL. Accordingly requested to set aside the order of the Ld.CIT(A) and restore the assessment order.

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strategic sale. The promoters also agreed that if required for the purpose of complying with the provisions of Law, the promoters shall offer the promoters shares for sale in QIPO, IPO, QSS or Strategic Sale as the case may be. If the company does not provide exit route as per clause 13.1., the company and the share holders are required to extend all cooperation and make arrangements for sale of shares of the investors even by using all it’s resources. For the sake of clarity, clause 13.2 reads as under. “13.2. No Exit Route. If the Company does not provide an exit route to the Investors as provided in Clause 13.1 above within the Exit Route Period, then at the sole option of the Investors, the Investors may require a. the Company and the Existing Shareholders to cooperate to arrange an offer for sale of all Shares held by the Investors through an IPO at a recognised stock exchange an terms and conditions determined by the Investors within a period of 120 (One Hundred and Twenty) days of receipt of a notice from the Investors; and/or b. subject to applicable Law, the Promoters shall exercise all their voting and :other rights in a manner such that the Company uses all of Its surplus funds, free cash flows and reserves available for each year to first buyback the Shares of the Investors at the higher of the valuation set out in definition of QIPO valuation or fair market value ("FMV"), i. Provided, however, that, notwithstanding anything else contained herein, the 'Existing Shareholders shall abstain from offering their Shares in a buy-back of Shares by the Company as provided in Clause 13.2(b) above; ii. In respect of Investor Preference Shares, the FMV for such Investor Preference Shares shall be determined based on the FMV of the underlying Equity Shares. The computation of the FMV of the Equity Shares shall be done by any Investment banker of international repute to be nominated mutually by the Investors and the Company in accordance with generally accepted valuation principles.”

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5.1. As per clause 13.4, all costs and expenses relating to the exit being provided to the investors under this Clause 13 shall be borne by the company. Therefore, the Ld.AR argued that exit route has not given any option to the company and the promoters and they are bound by agreement for offering their shares as per the agreement reached between the company and the investors to honour the commitment. Therefore, the company M/s TMPPL has entered into an arrangement with M/s Barclays Bank through EL to provide financial advice and related assistance to the client in connection with possible transaction involving the client. For the purpose of this EL, “the transaction means the sale, howsoever effected and whether undertaken in one or series of transactions of the client or of all or any part of the client’s business and assets and or any other means by which control of or an investment in, the client is obtained”. The scope of engagement was financial advisor in connection with the transaction, assist the client in identifying and liaising with the potential purchasers. From plain reading of the EL, it is very clear that the company M/s TMPPL has engaged M/s Barclays as a financial advisor for possible business transaction. The letter was not for the sale of shares, it is for identifying and liaisoning the potential buyer and its advisors for the transaction.

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There was no agreement between the assessee and M/s Barclays to evaluate the shares and it was for valuation of the assets for a possible transaction for identifying the assets to be sold to the potential buyer.

5.2. The Ld.AR further stated that though the assessee was forced to sell the shares in accordance with the agreement entered with the Carlyle Goup, the assessee was put into loss personally since there is no plans made by the assessee to invest such huge amount. The company has to provide exit route to Carlyle Growth by 31.03.2014. For the purpose of honouring the obligation, M/s TMPPL has issued EL to M/s Barclays Bank PLC for financial advice and possible transaction, to study the market and find the way to provide the exit route to Carlyle Group. The intention of entering into EL with Barclays bank was to find strategic investor who could buy the entire shareholding of Carlyle group with a pre determined evaluation agreeable. As per the terms of the EL, it was entitled for success fee, if they are successful in finding the strategic investor. Barclay was successful in identifying the investor namely BSA International but it was reluctant to buy the shareholding of Carlyle alone, instead, insisted on buying the entire shareholding of TMPPL including that of Carlyle group and 41 promoters for the transaction to materialize. TMPPL having

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committed to the Carlyle Group in the PE agreement to find exit route by 31.03.2014, convinced its promoters to sell their shareholding much against their wish. Neither the assessee nor other co promoters were parties to the EL issued to the Barclays Bank.

5.3. The Ld.AR advancing the argument that the assessee was not the director at the time of raising the invoice and to invoke the provisions of section 2(24)(iv) of the Act stated that as per the understanding, the assessee and other promoter directors have resigned from the Board of Directors of TMPPL w.e.f. 07.01.2014 and the representatives of BSA International took over the management of TMPPL immediately. The process of transfer of shares was completed on 07.01.2014 and the consideration was transferred to the assessee. At the time of happening both the incidents of raising the invoice and making the payment to Barclays by TMPPL the assessee ceased to be the shareholder / Director of the company. Barclays has raised invoice on TMPPL regarding success fee of Rs.28.81 crores on 08.01.2014 and TMPPL has paid to Barclays Bank subsequently. Both the incidents of receiving the invoice and making payment to Barclays by TMPPL had happened after the assessee ceased to

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be the Director of the company. No benefit whatsoever was received directly or indirectly by the assessee from TMPPL on account of success fee paid to Barclays bank. The proportionate success fee was recovered by the buyers from the consideration payable to assessee much ahead of receiving invoice) therefore, the Ld.AR argued that the Ld.CIT(A) has rightly held that there was no duty or obligation cast upon the assessee for payment of success fee and the same cannot be treated as income in the hands of the assessee since the amount was already recovered from the net consideration paid to the assessee. No benefit was derived by the assessee and it was reduced before receiving the consideration by the assessee. Even otherwise also, the assessee was ceased to be Director as on the date of raising the invoice, hence, the question of attracting 2(22)(iv) does not arise, accordingly argued that there is no interference is called for in the order of the Ld.CIT(A) and the order of the Ld.CIT(A) to be upheld.

While releasing the consideration, buyers calculated the proportionate amount of Rs.2,97,92,811 from the consideration payable for the shares held by the assessee and released the net consideration to the assessee, even though the payment of success fee was the obligation of TMPPL and not that of the assessee. Thus the Ld.AR argued that success fee

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was deducted at source from the funds of the shareholders, hence, no benefit whatsoever received by the share holders and no need to tax the same u/s 2(24)(iv) of the Act.

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company partly / fully. As per Clause 2.2. the company agrees that it shall be responsible for all costs and expenses and the Barclays has raised invoice on client in accordance with the EL. M/s Barclays identified the potential buyer, i.e BSA International Ltd to take over the company not only the interest of Carlyle Group but also expressed its interest to take over the shares of individual shareholders, thereby taking hold of the entire company. It was stated by the assessee that BSA International was reluctant to buy the shareholding of Carlyle Group alone. Therefore as explained by the Ld.AR, TMPPL has convinced its promoters to sell their shareholding against their will. The shareholders did not engage the Barclays and the intention of the EL was to identify the potential buyer as observed by the Ld.CIT(A). EL was executed on 05.07.2013 and it was not meant for transfer of shares. It provides for sale of business or assets and for possible transaction and there was no certainty with regard to possible transaction at the time of execution of the EL. As per the EL, success fee is to be paid by M/s TMPPL on completion of the transaction. Subsequent to identifying the potential buyer of the company, the individual shareholders were compelled to sell the shares to BSA International which cannot be held against the assessee to hold that the assessee got the benefit. Since the

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assessee was not the party to Barclays for EL, there is no legal obligation on the part of the assessee to make the payment and the same is not enforceable against the assessee. The agreement is between the Barclays Bank and M/s TMPPL, but not between the shareholders and the Barclays. Thus, there was no legal liability of shareholders to make the payment. The AO did not furnish any material to show that the assessee had engaged the Barclays and the company made the payment on behalf of the assessee to derive the benefit directly or indirectly. As per section 2(22)(iv) of the Act, any sum paid by any such company in respect of any obligation which is required to be paid for the Director or shareholder has to be treated as income in the hands of such Director. In the instant case, there is no evidence to show that the assessee had entered into agreement for transfer of shares or the assessee was obliged to make payment to Barclays. As per the EL, Barclays was engaged as a sole financial advisor in connection with the transaction and no other person should be appointed by TMPPL. It was also made clear that the promoters or the client may choose and appoint their own consultant or advisor. Such consultant has no right to claim the fee, right title for the purpose of carrying out the services contemplated. The Directors or shareholders are permitted to appoint their own

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consultant who will not have any say in the success fee. In view of this clause also, the contention of AO that the success fee was the obligation of the assessee is incorrect. As mentioned in the share purchase agreement (SPA), cost of transfer of shares should be borne by the assessee. Accordingly, the expenses in relation to the negotiation, finalization and execution of SPA have to be borne by the shareholders including the assessee. The success fee was for engaging the services of Barclays as per EL dated 05.07.2013 and the share purchase agreement was entered on 04.11.2013, much ahead of SPA, hence, the success fee cannot be treated as the expenditure incurred in connection with the SPA. From plain reading of SPA and the EL, it is established that the assessee has no obligation to make any payment towards success fee paid to Barclays, hence, it cannot be held that the assessee got any benefit from the success fee paid by the TMPPL as observed by the Ld.CIT(A). Accordingly, we uphold the order of the Ld.CIT(A) and dismiss the revenue’s ground on this issue.

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payment made, all the Directors have relinquished and they were no more Directors. Hence argued that having ceased to be the director of the company by the time the payment was made, section 2(24)(iv) has no application in assessee’s case. The AO rejected the contention of the assessee stating that the obligation of the assessee arose on the date of agreement dated 05/07/2013 when the assessee was a director of the company and holding substantial stake in the company, hence rejected the argument of the assessee. As per the discussion made in the preceding paragraphs we have held that the there was no benefit derived by the assessee and once it is held that the assessee did not derive any benefit the issue becomes infructuous. However, it is also a fact that the assessee ceased to be director /shareholder by the time the invoice was raised and the payment was made. The new directors taken the decision to make the payment. Hence it is incorrect to apply the provisions of section 2(24) (iv) in the case of the assessee.

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the CIT(A) order, wherein, the details were furnished with regard to evaluation of the company and purchase consideration agreed to be paid by BSA International which was calculated by Deloitte Touche Tohmantsu India Private Ltd which reads as under :

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8.1. From the above working, it shows that Barclays fee was already recovered by BSA International and the net consideration was paid to shareholders which establishes that the amount of succession fee paid to Barclays from the profits and reserves of the shareholders. Further, the fee paid to Barclays was expenses in relation to transfer of shares which

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required to be allowed as deduction for computing the capital gains and cannot be brought to tax under the head ‘income from other sources’. For a query from the Bench, the Ld.DR did not show any material to substantiate that the success fee paid to the Barclays was not in relation to transfer of shares. Accordingly, we uphold the order of the Ld.CIT(A) and dismiss the appeal of the revenue.

I.T.A.No.12/VIZ/2019, A.Y.2014-15 9. Brief facts of the case are that the assessee is an individual filed his return of income on 27-09-2014 for the asst. year 2014-I5 admitting total income of Rs. 210,99,86,140/- from salary, advisory fees, house property, capital gains and income from other sources. Subsequently, the case was selected for scrutiny under CASS and appropriate notices were issued by the AO and duly served upon the assessee. During the course of proceedings the AO noticed that the income of the assessee consists of long term capital gains of Rs. 204,17,20,233/- on sale of shares of M/s Tirumala Milk Products Pvt. Ltd.(TMPPL). The AO considering the payment made by the company TMPPL to M/s. Barclays Bank PLC (BBP) towards success fee reduced the capital gains admitted by the assessee to the extent of Rs.3,70,24,915/- and the same was treated as other source of income. In

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effect there was no change in the income admitted by the assessee and income assessed by the AO. The sum of Rs. 3,70,24,915/- was considered as other source of income from other sources instead separately which has the effect of increasing the tax rate.

9.1. On identical facts in the case of Danda Brahmanandam vide I.T.A 11/Viz/2019 in this order we have held that no benefit was derived by the assessee on transfer of shares and upheld the order of the Ld.CIT(A). Accordingly, we hold that the payment of success fee is the obligation of the company since the agreement was entered into by the assessee company and the Barclays, hence we hold that no personal benefit derived by the assessee and we do not find any reason to interfere with the order of the Ld.CIT(A) and the same is upheld.

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Order pronounced in the open court on 19th Jul 2019.

Sd/- Sd/- (िी.दुगाा राि) (धड.एस. सुन्दर धसंह) (V. DURGA RAO) (D.S. SUNDER SINGH) न्याधयक सदस्य/JUDICIAL MEMBERलेखा सदस्य/ACCOUNTANT MEMBER नवशधखधपटणम /Visakhapatnam नदनधंक /Dated :19.07.2019 L.Rama, SPS

आदेश की प्रतितिति अग्रेतिि/Copy of the order forwarded to:- 1. ननधधाऩरती/ The Assessees – (i) Sri Danda Brahmanandam, 13AJ Block, 5th Street, Santhi Colony, Annanagar, Chennai (ii) Sri Battini Nageswara Rao, D.No.11-15-8, Ramireddy Pet, Narsaraopet Guntur 2. रधजस्व /The Revenue - Asst.Commissioner of Income Tax, Circle-2(1), Guntur 3. The Pr.Commissioner of Income Tax-1, Guntur 4. The Commissioner of Income Tax (Appeals)-1, Guntur 5. तिभागीय प्रतितिति, आयकर अिीिीय अतिकरण, तिशाखािटणम/DR, ITAT, Visakhapatnam 6. गार्ड फ़ाईि / Guard file आदेशािुसार / BY ORDER // True Copy //

Sr. Private Secretary ITAT, Visakhapatnam