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Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH, VISAKHAPATNAM
Before: SHRI V. DURGA RAO& SHRI D.S. SUNDER SINGH
आदेश /O R D E R Per D.S. Sunder Singh, Accountant Member : These appeals are filed by the revenue against the orders of the Commissioner of Income Tax (Appeals) [CIT(A)]-1, Guntur vide I.T.A No.98/CIT(A-1)/GNT/2014-15 dated 30.12.2016 and 70/2016-17/CIT(A- 1)/GNT dated 30.01.2017 and the cross objections are filed by the assessee in support of the orders of the CIT(A) for the A.Y.2011-12. Since the facts of the case are identical, these appeals are clubbed, heard together and a common order is being passed. Since the facts are identical the same are
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extracted from the records of Yalavarthi Srinivasa Rao (HUF) in I.T.A 145/Viz/2017 for the sake of convenience.
Ground Nos. 1 and 9 are general in nature which does not require specific adjudication.
Ground No. 2 to 5 are related to the adoption of fair market value(FMV) of the property as on 01.04.1981 for computing the capital gains. During the impugned assessment year, the assessee has sold the property bearing No.12-25-126 situated at Kothapet, Guntur for a consideration of Rs.1,32,00,000/- as per the sale document No.9635/10 dated 27.09.2010. The property was valued by the stamp valuation authority at Rs.2,15,00,000/- on which the assessee also has paid the stamp duty. The said property consisting of 730 sq.yds of site and the building was received by way of partition deed dated 16.02.1972 by Y. Srinivasa Rao and his brother Shri Surendranath . The assessee has taken the fair market value of the property as on 01.04.1981 at Rs.25,00,000/- and claimed the expenses relating to improvements of Rs.4,50,000/- stated to be incurred during the financial year 1982-83 and Rs.5,60,000/- during the F.Y.2010-11 and admitted the long term capital gains of Rs.1,14,839/- to wards his
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share of 50%. The AO conducted enquiries with SRO, Guntur for ascertaining the value of the property as on 01.04.1981 and the Sub Registrar, Guntur vide his letter dated 28.02.2014 informed the guideline value of the land at Rs.70/- per sq.yd and Rs.34.10 per sq.ft for RCC structure and Rs.24.10 per sq.yd for ACC structure as on 01.04.1981. Therefore, the Assessing Officer (AO) viewed that the assessee had claimed the excess deduction towards the FMV and hence, issued the show cause notice calling for the explanation of the assessee as why the fair market value of the property should not be adopted as per SRO rates. In response to the show cause notice, the assessee has stated that he had received the land and building consisting of 730 sq.yds by partition and subsequently made the improvements of Rs.4,50,000/- in the year 1982-83 along with his brother Sri Y.Surendranath and incurred building repairs of Rs.5,60,000/- in the year 2011-12. The assessee explained that the property was located in commercial area and proximate to the Railway stations, cinema theatres and other commercial establishments and the FMV of the property as on 01/04/1981 was Rs.25,00,000/-.The assessee further stated that the SRO value is guideline value which is one among the guiding factors but such guide line values need not be the market values all
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times. Hence requested the AO to accept the FMV adopted by the assessee and not to make any addition. The assessee also furnished the copy of the approved valuer’s report valuing the property at Rs.26,68,000/- as on 01.04.1981. The AO did not accept the fair market value adopted by the assessee at Rs.25,00,000/- and computed the capital gains at Rs.2,02,17,679/-. The assessee has claimed the improvements made to the building at Rs.4,50,000/- for the F.Y. 1982-83 and Rs.5,60,000/- for the F.Y. 2010-11. The AO did not allow Rs.4,50,000/- and has not given any reason for rejecting the claim made by the assessee and in respect of Rs.5,60,000/- , the AO allowed expenditure of Rs.3,00,000/- and the balance was disallowed while computing the capital gains.
Aggrieved by the order of the AO, the assessee went on appeal before the CIT(A) and the Ld.CIT(A) deleted the additions made by the AO and directed the AO to accept the capital gains disclosed by the assessee at Rs.1,14,839/- and accordingly allowed the appeal of the assessee.
Against the order of the Ld.CIT(A), the revenue is in appeal before us and the assessee filed cross objections supporting the order of the Lfd.CIT(A). During the appeal hearing, the Ld.DR supported the order of
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the AO and argued that the assessee did not furnish any evidence to show that the fair market value as on 01.04.1981 was Rs.25,00,000/-. Approved valuer has valued the FMV at Rs.26.68 lacs without any basis, hence not acceptable. The AO has conducted the enquiries with SRO, Guntur, who had furnished the details of guideline values regarding the valuation of surrounding properties as on 01.04.1981 and the Ld.DR argued that the AO had computed the capital gains adopting the FMV of the property as per the guideline value of the Sub Registrar office. Therefore, submitted that the AO has rightly computed the capital gains at Rs.2,03,60,929/- which should be upheld. In respect of improvement expenses for the financial year 1982-83 the Ld.DR argued that the expenses were disallowed by the AO for want of evidence. The Ld.DR submitted that there is no case for allowing the expenditure in respect of improvements, hence requested to uphold the order of the AO and set aside the order of the Ld.CIT(A).
On the other hand, the Ld.AR submitted that there was a mistake in the assessment order passed by the AO in computing the total capital gains in the hands of Sri Srinivasa Rao instead of his share of 50%. The property in question was joint property of Shri Y.Srinivasa Rao and Shri Y.Surendranath the brothers. The Ld.AR submitted that the property was
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received on partition on 16.02.1972 and subsequent to receipt of the property, the co-owners have incurred expenses of Rs.4,50,000/- for the financial year 1982-83 and Rs.5,60,000/- for improvements. For the purpose of computation of capital gains the assessee made the enquiries of FMV as on 01/04/1981 which was stated to be Rs.25,00,000/- in view of the locational advantage, hence adopted the FMV as on 01/04/1981 at Rs.25,00,000/- and computed the capital gains. The property was referred to the registered valuer who had valued the property at Rs.26,68,000/- after making enquiries and considering the proximity to the commercial areas. The property was located at Kothapet, which is a commercial area in the heart of the city, nearer to railway station, bus stand, cinema theatres, hospitals etc.. Therefore, submitted that after taking into consideration, all the above advantages, the property was valued at Rs.25,00,000/- which is correct valuation and accepted by the Ld.CIT(A). The Ld.AR further argued that the SRO has not taken any of the factors regarding location of the property, nature of the property etc.. therefore, argued that fair market value cannot be adopted as per Sub Registrar’s guideline value and it should be taken as per the market value. The Ld.AR argued that no interference is called for in the order of the Ld.CIT(A).
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We have heard both the parties and perused the material placed on record. At the outset, we observe that the assessee is 50% owner of the property. Both the assessee and his brother Sri Y.Surendranath have acquired this property by partition deed dated 16.02.1972. Therefore, capital gains required to be assessed equally between the assessee and his brother. The assessee has sold the property for a consideration of Rs.1,32,00,000/- vide sale document No.9635/10 dated 27.09.2010 and the property was valued at Rs.2,15,00,000/- by stamp valuation authority and the assessee has paid the stamp duty and admitted the capital gains at Rs.1,14,839/- as under : Financial Acquisition Details Cost Indexed Cost Year BUILDING INHERITED WITH VACANT 1981-82 25,00,000 1,77,75,000 SITE JOINTLY WITH BROTHER VIDE PARTITION DEED 16/02/1972 FAIR MARKET VALUE AS ON 01/04/1981- 2500000*711/100 Improvement Details Improvement made to the building – 1983-83 4,50,000 29,35,321 450000 * 711/109 Improvements made towards building 2010-11 5,60,000 5,60,000 development – 560000 * 711/711 Indexed Cost of Improvement Capital Gain 34,95,321 Taxable Capital Gain 2,29,679 Share of Capital Gain 2,29,679 1,14,839
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7.1. As per the computation of capital gains, the assessee has taken the fair market value as on 01.04.1981 at Rs.25,00,000/-. The assessee has furnished valuation report from M.R.K.ParamaHamsa, Govt. Registered Valuer who has valued the property at Rs.26,68,000/- as under: Value of the Land Market Value of Land varies between Rs.2,000 to Rs.3,000 per sq.yd Hence Value of the Land as per My Valuation taking the Middle Value is 730 x 2000 = Rs.14,60,000 – 00 Vale of the Building I can consider the cost of RCC Construction @Rs.400/- per sq.ft I can consider the cost of ACC Construction @200/- per sq.ft as on April, 1981 Hence, Value for RCC Ground Floor is : 2520 x 400 = Rs.10,08,000-00 Vale of ACC First Floor is : 1000 x 200 = Rs. 2,00,000-00 Net Value of the Building as on April, 1981 is : Land Value + Ground Floor Value + First Floor Value i.e.Rs.14,60,000+10,08,000+2,00,000 = Rs.26,68,000-00 (Rupees Twenty Six Lakhs Sixty Eight Thousand only) The AO called for information from the SRO, Guntur who has given guideline value as on 01.04.1981 at Rs.70/- per sq.yd for site and Rs.34.10/- per sq.ft for RCC building and Rs.24.10 per sft for ACC building. The indexed cost of the acquisition as per guideline value worked out to Rs.11,45,648/- as worked out by the AO in the case of Surendranath. The AO rejected the FMV adopted by the assessee. However, the AO did not give any reason for rejecting the fair market Value adopted by the assessee which was supported by the Registered Valuer’s report. As per the
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provisions of I.T.Act., for computing capital gains of the properties acquired prior to 01.04.1981,the fair market value as on 01.04.1981 required to be taken as cost of acquisition. The SRO office gives the guide line value of the properties in and around surrounding areas, but not the fair market value of the property. Therefore, the guideline value cannot be taken as fair market value. Fair market value is the market value which fetches the value of the property in the same locality as on that date. In the instant case, the assessee has valued the property at Rs.25,00,000/- and in support of his claim, furnished the registered valuer’s report who is a qualified engineer and approved registered valuer for valuing the properties including the Income Tax department. Once, the Income Tax department gives licence to the registered valuer for valuing the property, the same cannot be brushed aside without valid reasons and examining the registered valuer. The assessee has submitted that the property was located at Kothapet and it was a commercial hub and located in the heart of the city and proximate to the railway station, bus stand, cinema theatres and hospitals etc.. All these factors were stated to be considered by the registered valuer and valued the fair market value as on 01.04.1981 at Rs.26,68,000/-. Whereas, the joint sub registrar has given a guideline value
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of the properties in and around the areas. Unless the joint sub registrar gives the complete details, building name, nature of structure etc.. the same cannot be accepted. Even otherwise, what the information submitted by the joint sub registrar is the guideline value, but not the fair market value. The word used in the Income Tax for the purpose of capital gains is not the guideline value, but the fair market value. In the instant case, the AO neither examined the registered valuer nor examined the joint sub registrar. The AO’s contention that the assessee has not produced any evidence to establish the fair market value as on 01.04.1981 is incorrect since, it was supported by the valuation report of the Govt. registered valuer, who has been authorized by the Income Tax department to value the properties. The AO did not collect any other evidence such as market information, the information published in news papers etc.. to support his argument to establish that the FMV adopted by the assessee is incorrect. Therefore, we uphold the order of the Ld.CIT(A) and hold that the fair market value as on 01.04.1981 at Rs.25,00,000/- is reasonable. The assessee relied on the decision of Hon’ble Andhra Pradesh High Court in the case of CIT Vs. Ashven Datla 37 taxmann.com 261 (A.P.), wherein the Hon’ble High Court held that for computing the capital gains u/s 48, fair
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market value of property cannot be determined on the basis of guideline value emanating from Sub-registrar’s office unless it is scientifically arrived at. Similarly, this Tribunal in the case of ITO Vs. Padarti Venkata Rama Chandra Rao vide I.T.A 216/Viz/2012 dated 16.09.2016 considered similar issue and held that the fair market value has to be taken for determining the cost of acquisition as on 01.04.1981, but not the guideline value. For the sake of clarity and convenience, we extract relevant part of the order of this Tribunal from para No. 9 to 12 which reads as under : “9. We have heard both the parties, perused the materials available on record and gone through the orders of the authorities below. The first issue that came up for our consideration is cost of acquisition of the property. The assessee has adopted cost of acquisition of the property as on 1.4.1981 based on the certificate of registered valuer. The A.O. has determined cost of acquisition of the property based on the SRO value of the property fixed by the State Government for the purpose of determination of stamp duty. The A.O. was of the opinion that cost of acquisition adopted by the assessee based on the registered valuer certificate is not in accordance with the provisions of section 48 & 49 of the Act. According to the A.O., when asset is acquired by the assessee by way of one of the mode specified u/s 49(1) of the Act, the assessee can either adopt cost to the previous owner or fair market value of the property as on 1.4.1981. According to the A.O., the fair market value of the property as on 1.4.1981 is as per the SRO value. 10. It is the contention of the assessee that he has adopted fair market value of the property based on the certificate of the registered valuer. The assessee further contended that the A.O. was not correct in applying SRO value as fair market value of the property, as the SRO value fixed by the State Government is not correct market value of the property. The A.O. was erred in equating with full value of consideration as a result of transfer to the fair market value of the property for the purpose of computation of cost of acquisition. We find force in the argument of the assessee for the reason that the A.O. was erred in adopting SRO value to substitute fair market value of the property for the purpose of computation of cost of acquisition of the property. Section 48 of the Act
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deals with the mode of computation of income chargeable under the head "capital gains" and in that context full value of consideration would mean the consideration or price received as a result of the transfer of a capital asset. It is different from fair market value of the property, which phrase is used in section 45(2) of the Act relating to capital gains and section 55(3)(b) in relation to cost of acquisition. 11. The legislature has expressly drawn a distinction between the two phrases 'full value of consideration' and 'fair market value'. The former would be the price received on transfer of capital asset and the later would be the price of a capital asset would ordinarily fetch on sale in open market on the relevant date. In the present case on hand, the assessee has adopted fair market value of the property as on 1.4.1981 as cost of acquisition which is based on a certificate issued by the registered valuer. The A.O. without assigning any reasons disbelieved registered valuer's report and adopted SRO value of the property for the purpose of determination of computation of cost of acquisition, when Act specifically provides powers to the A.O. under the provisions of section 55(2) of the Act, to refer the valuation of the property to the valuation officer, when he is of the opinion that the fair market value of the property adopted by the assessee is higher than the fair market value of the property. The A.O., without exercising the option of referring the matter to the valuation officer, simply adopted SRO value which is fixed in a different context to determine the cost of acquisition of the property. Therefore, we are of the opinion that the A.O. was erred in adopting SRO value to substitute the fair market value adopted by the assessee, which is based on a registered valuer certificate. 12. Now it is pertinent to discuss here the case law relied upon by the assessee. The assessee has relied upon the decision of Hon'ble Karnataka High Court in the case of N. Govindaraju Vs. ITO & Anr. 377 ITR 243, wherein the Hon'ble High Court under similar circumstances held as under:
"Section 48 of the Act deals with the 'Mode of Computation' of income chargeable under 'Capital gains' and in that context 'full value of the consideration' would mean the consideration or price received as a result of the transfer of a capital asset. It is different from 'fair market value' of the property, which phrase is used in section 45(2) [relating to capital gains] and section 55(2)(b) [relating to cost of acquisition]. (para 44) The legislature has expressly drawn a distinction between the two phrases: 'full value of the consideration' and 'fair market value The former would be the price received on transfer of a capital asset and the latter would be the price that a
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capital asset would ordinarily fetch on sale in open market on the relevant date. (para 47) Assessee had provided the reasons for determining Rs.225/- per sq. ft. as the fair market value of the property by producing the relevant material, including valuation report of a registered valuer, which all have been ignored while arriving at the price of Rs 84/- per sq. ft. The Assessing Officer assessed the value of the property as on 1. 4.1981 on the basis of sale deeds of some nearby properties registered for such price in the year 1981 and thus, arrived at that figure. In our opinion, the same cannot be the proper mode of arriving at the 'fair market value' of the property in question as on 1.4.1981, for the purpose of determining 'Capital gains' under the Act. (para 48) Tribunal was not justified in arriving at the fair market value of the property in question as on 1. 4.1981 without taking into consideration the material on record, including the valuation report filed by the assessee. The matter thus requires to be remanded to the Assessing Officer for determination of the fair market value of the property in question in accordance with law and in the fight of the observations made hereinabove. (para 51)"
7.2. From the above judicial precedent it clear that for computing capital gains it is FMV to be adopted but not the guideline value. In the instant case, the assessee has valued the fair market value as on 01.04.1981 at Rs.25,00,000/-, considering the locational advantages of the property. The assessee also supported its valuation by the report of Govt. Registered Valuer, who has also valued the property at Rs.26,68,000/-. The AO simply rejected the valuation report without assigning any reason or examined the registered valuer. Therefore, having held that it is not the guideline
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value which is to be considered for determining the capital gains and it is the fair market value since the AO did not bring any evidence to show that the fair market value was lesser than Rs.25,00,000/- or report of the approved valuer is faulty, we have no hesitation to hold that the fair market value of the property as on 01.04.1981 is Rs.25,00,000/-. Accordingly, we uphold the order of the Ld.CIT(A) and dismiss the appeal of the revenue on this ground.
Ground No.6 to 8 are related to the claim of expenditure towards the improvements which has effect on the quantification of income from long term capital gains. In the computation of capital gains, the assessee claimed the deduction towards improvements i.e. Rs.4,50,000/- incurred during the financial year 1982-83 and Rs.5,60,000/- during the financial year 2010-11. The AO allowed Rs.3,00,000/- out of Rs.5,60,000/- for F.Y2010-11 but did not allow Rs.4,50,000/- which was incurred in the financial year 1982-83. In the case of Sri Yalavarthi Srinivasa Rao, the AO did not even give any reason for not allowing the expenses incurred for improvements for the financial year 1982-83. However, from the order of Sri Yalavarthi Surendranath, we observe that a sum of Rs.4,50,000/- was
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disallowed for want of evidence such as agreement and the details of payments etc.
8.1. In respect of expenditure incurred for the A.Y. 2011-12, out of Rs.5,60,000/-, the AO has allowed Rs.3,00,000/- in the absence of documentary evidence. Therefore, against the order of the AO, the assessee went on appeal before the CIT(A) and the Ld.CIT(A) allowed the appeal of the assessee.
8.2. Against the order of the Ld.CIT(A), the revenue has filed appeal before this Tribunal.
We have heard both the parties and perused the material placed on record. With regard to the expenditure for improvements in the financial year 1982-83, the assessee stated that he had incurred the sum of Rs.4,50,000/- jointly for improvements of the property. The assessee has further stated that the expenditure was incurred through Ramakrishna Reddy who is building contractor towards building repairs. However, the assessee has not produced the agreements in support of its claim nor the details as to how the payments were made relating to renovation work. The issue is very old and the expenses were incurred in the F.Y 1982-83 more
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than 30 years and the amount involved was only Rs.4,50,000/. The assessee has furnished the details of the contractor through whom the improvements were made. The assessing officer did not make any enquiries with the contractor. The assessee is an individual/HUF having only source of income from other sources and capital gains. The property was received in 1972 and the improvements were made in 1982-83 for an individual who has only source of income from other sources generally do not maintain proper records and keep them for such a long time. Considering all the facts and circumstances we do not see any reason to disbelieve the improvements claimed by the assessee. Accordingly, we hold that the assessee should be allowed the expenses for improvements in 1982-83 and we do not find any reason to interfere with the order of the CIT(A) and the same is upheld.
The next issue is the improvement expenditure of Rs.5,60,000/-. The assessee has stated that the expenditure of Rs.5,60,000/- was incurred in the financial year 2010-11 and there is no reason for not furnishing the complete details. The AO allowed Rs.3,00,000/- out of Rs.5,60,000/- claimed by the assessee. During the appeal hearing though the assessee has furnished the details of expenditure, since it was not furnished before
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the AO, we hold that the disallowance made by the AO is reasonable. Accordingly, we set aside the order of the Ld.CIT(A) and allow the appeal of the revenue on this ground.
Cross Objections are filed by the assessee in support of the order of the Ld.CIT(A). Since the revenue’s appeals are partly allowed, the cross objections also stand partly allowed.
In the result, appeals of the revenue as well as the cross objections of the assessee are partly allowed. Order pronounced in the open court on 30th April 2019.
Sd/- Sd/- (िी.दुगाा राि) (धड.एस. सुन्दर धसंह) (V. DURGA RAO) (D.S. SUNDER SINGH) न्याधयक सदस्य/JUDICIAL MEMBER लेखा सदस्य/ACCOUNTANT MEMBER नवशधखधपटणम /Visakhapatnam नििधंक /Dated : 30.04.2019 L.Rama, SPS
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आदेश की प्रतितिति अग्रेतिि/Copy of the order forwarded to:- 1. रधजस्व/ The Revenue –Income Tax Officer, Ward-2(2), Guntur 2. निर्धाऩरती/ TheAssessee-(i) Yalavarthi Srinivasa Rao (HUF), D.No.4-1-10/1 4th Line, Lakshmipuram, Guntur (ii) Yalavarthi Surendranath (HUF) Flat No.20, Kamalesh Enclave, 6/1, Chandramouli Nagar, Guntur 3. The Pr.Commissioner of Income Tax,Guntur 4. The Commissioner of Income-Tax (Appeals)-1, Guntur 5. तिभागीयप्रतितिति, आयकरअिीिीयअतिकरण, तिशाखािटणम/DR, ITAT, Visakhapatnam 6.गार्डफ़ाईि / Guard file आदेशािुसार / BY ORDER // True Copy //
Sr. Private Secretary ITAT, Visakhapatnam