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Income Tax Appellate Tribunal, JAIPUR BENCHES, JAIPUR
Before: SHRI VIJAY PAL RAO, JM & SHRI VIKRAM SINGH YADAV, AM vk;dj vihy la-@ITA. No. 13/JP/2017
आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR Jh fot; ikWy jko] U;kf;d lnL; ,oa Jh foØe flag ;kno] ys[kk lnL; ds le{k BEFORE: SHRI VIJAY PAL RAO, JM & SHRI VIKRAM SINGH YADAV, AM vk;dj vihy la-@ITA. No. 13/JP/2017 fu/kZkj.k o"kZ@Assessment Years : 2013-14 cuke G.D. Minerals, ACIT, Circle-1, Vs. Jaipur Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAKFG1716B vihykFkhZ@Appellant izR;FkhZ@Respondent
fu/kZkfjrh dh vksj ls@ Assessee by : Shri Rajeev Sogani (CA) jktLo dh vksj ls@ Revenue by : Shri Raj Mehra (JCIT) lquokbZ dh rkjh[k@ Date of Hearing : 30/11/2017 mn?kks"k.kk dh rkjh[k@Date of Pronouncement : 08/12/2017 vkns'k@ ORDER
PER: VIKRAM SINGH YADAV, A.M. This is an appeal filed by the assessee against the order of ld. CIT(A), Jaipur dated 08.11.2016 for Assessment Year 2013-14 wherein the assessee has taken the following two grounds of appeal:- “1. In the facts and circumstances of the case and in law, the ld. CIT(A) has grossly erred in confirming the action of ld. AO in making addition of Rs. 6,58,553/- on account of disallowance of commission u/s 40A(2)(b) of Income Tax Act, 1961. The action of the ld. CIT(A) is illegal, unjustified, arbitrary and against the facts of the case. Relief may please be granted by deleting the said addition Rs. 6,58,553/-.
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In the facts and circumstances of the case and in law the ld. CIT(A) has grossly erred in confirming the action of ld. AO in making addition of Rs. 30,00,000/- on account of disallowance of supervision charges claimed as business expenditure. The action of ld. CIT(A) is illegal, unjustified, arbitrary and against the facts of the case. Relief may please be granted by deleting the said addition Rs. 30,00,000/.”
Regarding ground No. 1, briefly stated, the facts of the case are that the assessee is a partnership firm engaged in the business of magnetic sorting of iron ore at the mines situated at Khetri, Jhunjhunu, Rajasthan. During the year under consideration, it paid commission of Rs. 5,00,000 each to Kishan Agarwal (HUF) and Gaurav Bansal (HUF) on total sales of Rs. 10,34,690/- made by these two HUFs. These two HUFs are specified persons covered u/s 40A(2)(b) of the Act. A show cause notice was issued by the AO to the assessee as to why excess commission payment should not be disallowed u/s 40A(2)(b) of the Act. In response, the assessee submitted that there was no fixed percentage of commission on turnover. It was further submitted that although turnover made by them is of less amount but commission has been paid to them on lumpsum basis hence it is not matching with the percentage of commission paid to other parties. It was observed by the AO that commission paid to other parties during the year, ranges between 27% to 37% and the average rate of commission comes to 33% whereas commission paid to these two HUFs were paid at a much higher rate of 97%. It was accordingly held by the AO that the commission of Rs 10 lacs paid to these two specified HUFs is excessive and unreasonable with regard to the fair market value of the services provided by them. The AO accordingly restricted the commission payment to Rs.
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3,41,447/- worked out at average rate of commission of 33% and disallowed the balance amount of Rs. 6,58,553/- u/s 40A(2)(b) of the Act.
Being aggrieved, the assessee carried the matter in appeal before ld. CIT(A) and contended that the AO has altogether ignored the fact that commission to these two related parties was paid being the minimum amount agreed between the appellant firm and the said parties. It was a business of the appellant firm to commit some minimum commission in order to make these parties agree to work for the appellant firm. It was further submitted that it is another issue that the decision later on turned out to be not as beneficial as it was thought initially. The reasonableness of the payments under section 40A(2)(b) is to be decided taking into account the prudence of a businessman and the AO has no right to sit in the armchair of the assessee and take a call later on about the correctness of the business decision of the assessee.
The ld. CIT(A) however was not impressed with the contentions so raised by the assessee firm and confirmed the subject disallowance and his relevant findings are reproduced as under:- “I have duly considered the submission of the appellant, assessment order and the material placed on record. The appellant has not brought on record the justification of lump sum payment of Rs. 5 lac each to these two HUFs covered u/s 40A(2)(b) of the Act as the commission payment was not commensurate with the services rendered by these entities. It is
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difficult to understand that how commission of Rs. 10 lac can be paid on total sales of Rs. 10,34,690/- made through these entities. The rate of commission payment to these two entities is 97% which is much higher than the average rate of commission @ 33% paid to other entities. The appellant has failed to brought on record any material which may justify the payment of such huge commission of 97% of the sale made through these two entities. The contention of the appellant that the AO cannot sit in the armchair of the assessee has no weight and deserves to be rejected looking to the peculiar facts and circumstances of the case. It is the duty of the AO to examine the payments to entities covered u/s 40A(2)(b) of the Act and the AO has appreciated the facts of the case in a correct perspective. The appellant has not brought on record copy of any agreement executed with these two HUFs for which commission was paid.”
During the course of hearing, the ld. AR reiterated the submission made before the CIT(A) which we have already noted above. It was further submitted that it is undisputed fact that the amount of commission which was paid to both the parties was the minimum amount of commission decided, irrespective of the sales made by the assessee firm through such parties. It was submitted that the assessee firm unfortunately could not derive the benefit to the fullest out of such commission paid. Even after efforts made to increase sales, the same could not be increased and the desired benefits could not be obtained. However, since the assessee firm had mutually decided with the parties with regard to the commission payment, the assessee firm had no other
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option but to remit the amount of commission payment and to honor the terms as agreed at the inception. It was submitted that it is common place, wherein agreements are entered by entities with other parties in which undertaking/guarantee is given to the service providers with regard to flow of minimum amount of benefit. This is normally done so as to ensure that the service provider/commission agent puts in his best foot forward and discharges its duties in accordance with the setout norms of the recipient of such services. It was submitted that the AO even though alleged that the commission payment made to the said parties was excessive however, ld. AO failed to point out any comparable instance to substantiate his claim. Under such circumstances, the commission amount paid to parties covered under section 40A(2)(b) cannot in any way be termed as unreasonable. Reliance was placed on the decision of the ITAT, Delhi Bench in the case of Sports Station (India)(P) Ltd. [2012] 23 taxmann.com 40 (Delhi) wherein it was held that “unless any material is placed to show that interest paid to persons covered under section 40A(2)(b) was excessive or any comparable instances in respect of fair market value of interest are cited, no disallowance can be made under section 40A(2)(a).”
It was further submitted that the ld. CIT(A), while rejecting the claim of the assessee firm committed the same error, as done by the ld. AO, in the assessment proceedings, of comparing the sales undertaken through such entities vis-à-vis the commission amount paid. Both the lower authorities have ignored the fact that the amount of commission was nothing but minimum amount undertaken to have paid by the assessee firm to such parties.
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It was further submitted that lower authorities committed error in comparing the two un-comparables to arrive at the excessive amount. The commission paid to both set of parties was on different terms and therefore cannot be compared to decide the excess amount. It is not the case of lower authorities that such terms of paying minimum commission are not in practice and without establishing this, excess amount worked out is erroneous.
The ld DR is heard who has relied on the order of the lower authorities.
We have heard the rival contentions and purused the material available on record. Firstly, the contention of the ld AR that the amount of commission which was paid to both the HUFs was the minimum amount of commission decided, irrespective of the sales made by the assessee firm through such parties remain unsubstantiated before us. There is nothing on record either in terms of written agreement or understanding between the assessee and these two HUFs or even where the agreement/understanding is verbal, the onus is on the assessee to bring on record some evidence by way of confirmation etc., which defines and lays down the terms of such engagement in terms of sales target, target customers/area, years of engagement, etc. The assessee has thus failed to discharge the said onus cast on it. Secondly, regarding the determination of excessive amount of commission so paid and the comparative cases whereby the onus is cast on the AO, we find that where the assessee itself is paying commission to other entities on the sales so made through them and
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where there is nothing on record to distinguish the nature of services so rendered by these entities vis-à-vis two HUFs, the said internal comparable cases have been rightly applied by the AO. In these comparable cases, the assessee itself is paying commission which ranges between 27% to 37% and in the instant case, the AO has thus taken the average of such commission which comes to 33%, compared it with the actual commission so paid by the assessee and has determined the excessive commission payment. We therefore donot find any infirmity in the action of the AO who has rightly disallowed the excessive commission under the provisions of section 40A(2)(b) of the Act and the action of ld CIT(A) who has sustained the same. Ground no. 1 is accordingly dismissed.
Regarding ground No. 2, briefly stated facts of the case are that the assessee firm has claimed supervision charges amounting to Rs. 39,50,000/- in its trading and profit and loss account as per details below:-
S. No. Name of the Party (Rs.) 1 Shakambari Enterprises 600,000 2 Nitin Jain HUF 700,000 3 Sukhmal Kumar Jain 500,000 4 Alka Jain 350,000 5 Renu Nathawat 480,000 6 Sushil Kanwar Nathawat 480,000 7 R.K.Agarwal HUF 840,000 Total 3,950,000
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During the course of the assessment proceedings, the assessee was asked about the details of the supervision charges. However, the AO observed that the reply of the assessee has been vague and unsatisfactory. Thereafter, notices were issued u/s 133(6) to all the 7 parties to which the AO observed that though compliance has been made in five cases in an identical manner however without any description whatsoever of the actual supervision services provided by them and in two cases, notices have been returned answered.
The AO, therefore, felt that the matter require further inquiry and investigation to establish the genuineness of the supervision services claimed to have been availed by the assessee firm. Thereafter, summons u/s 131 were issued to the 5 parties namely R.K. Agarwal (HUF), Nitin Jain(HUF), Sukhmal Kumar Jain, Ms Sushil Kanwar Nathawat and Miss Renu Nathawat. It would be relevant to refer to the order-sheet entry dated 13.01.2016 wherein the reasons have been recorded by the AO for issuance of the summons u/s 131 to the above said 5 parties which is reproduced as under:
“1. R.K. Agarwal (HUF), Nitin Jain(HUF) and Sukhmal Kumar Jain: First of all, the addresses of Nitin Jain (HUF) and Sukhmal Kumar Jain are exactly identical and the letters of confirmation sent by both are exactly identical with even the signatures being done in identical handwriting, very apparently appearing fake. Moreover, Sukhmal Kumar Jain’s date of birth is appearing to be 27.10.1945 which means he is around 71 years old. It is highly questionable as to how can a person of this age do any supervision work and that too in iron ore mines site in Khetri.
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Another reason for need of verification is that both R.K. Agarwal HUF and Nitin Jain HUF are getting fees for supervision and it is not clear as to why the supervision is being done by the HUF and not in individual capacity. In fact, even the handwriting on the envelopes in which confirmation have come of Nitin Jain HUF, Sukhmal Kumar Jain, Alka Jain & one R.N. Forging Pvt. Ltd. (for commission) is exactly identical & sent by the same person. The person who had come to submit the confirmation of R.K.Agarwal HUF had also come from the office of the A/R Sh. Abhishek Dalmia, as revealed when enquired by the Inspector of this Office. 2. Renu Nathawat and Sushil Kanwar Nathawat: Both of them were issued letters u/s 133(6) on 12.10.2015 which were dispatched through the Indian Post but both the letters came back unserved with the remarks, “Unclaimed” 19.10.2015. Later, when the A/R was confronted and asked to produce the parties for verification vide order sheet entry dated 21.12.2015, he replied on 05.01.2016 that the two parties would reply as he has intimated them. On 6th December, two identical letters were submitted to the office by the name of the two ladies who claimed same baby problems/health problem & hence pleaded non-appearance. It is highly questionable as to how two ladies, one aged 30 years and another aged 51 years could not appear in the office situated just 9.1 km away from their residence but could go for supervision on the site situated at Khetri Jhunjhunu situated 155 km away from their residence.
Therefore, the entire evidence and pleadings appear highly fabricated and unacceptable. Thus, it needs to be verified through personal
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appearance of the above parties. This need also arises from the fact that the A/R has in the previous hearings also been unable to explain about the modus operandi of the business undertaken. There is huge commission paid with respect to the turnover and huge supervision fees paid, all resulting in low net profit, also the reason for selection in CASS.”
In response to the summons, the AO observed that all the summons were duly served on the respective parties but none of the parties appeared on the date mentioned in the summons and similar letters, in similar handwriting, dispatched around the same time, with similar reasons for non-appearance were submitted. It was accordingly held by the AO that the onus lies on the assessee to prove the genuineness of the transaction, the identity of the persons and the actual performance of services for which such parties have been paid. However, despite sufficient opportunity being provided to the assessee, it failed to establish the genuineness of the transactions and the justification for the payment towards the supervision charges paid to these parties and the supervision charges of Rs. 30,00,000/- paid to these 5 parties cannot be allowed as a business expenditure. It was accordingly disallowed and brought to tax in the hands of the assessee.
Being aggrieved, the assessee carried the matter in appeal before the ld. CIT(A) and it was submitted that allowing the deduction of Rs. 9,50,000/- to two entities establishes the fact that AO was convinced about the services of supervision received by it and summons to all the parties were duly served which is accepted by the AO at page 8 of the
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assessment order. The AO had all the authority under the law to enforce the attendance of these persons and the AO has not exercised the said authority for the reasons best known to him. It was further submitted that disallowing the sum simply for the reason for non appearance is not at all justified when no other material is brought on record by the AO that the said payments or the parties were non genuine or the services were not received. It was further submitted that similar supervision charges paid by the appellant firm for similar services for AY 2012-13 were accepted by the department and the assessment for the said year was completed under section 143(3) of the Act. The ld. CIT(A) however, confirmed the disallowance of supervision charges of Rs. 30,00,000/-. Now, the assessee is in appeal before us.
During the course of hearing, the ld. AR submitted that the following facts remain undisputed namely, computation, ITR and Bank Statement of the parties, whatever applicable, evidencing the receipt of supervision charges by them were submitted to the ld. AO. All summons issued by the ld. AO, u/s 131, were served on all the parties. All the letters in response to notice under section 133(6) were provided to the ld. AO.
It was further submitted that the d. CIT(A), rejected the claim of the assessee for the reason that none of the parties appeared before the ld. AO in response to summons issued under section 131 of the Act is unjustified. As the assessee firm under the law has no power to enforce attendance of any person merely because no compliance was made with respect to summons issued under section 131, no additions can be
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made in the hands of the assessee firm. It is the duty of the Income Tax Authorities to bring summons issued, under section 131, to a logical conclusion. The said ratio has been laid down by the Hon’ble Supreme Court in the case of Orissa Corpn Pvt. Ltd. [1986] 25 taxman 80F (SC), wherein it is held that “….in this case the assessee had given the names and addresses of the alleged creditors. It was in the knowledge of the revenue that the said creditors were the income-tax assessee. Their index number was in the file of the revenue. The revenue, apart from issuing notices under section 131 at the instance of the assessee, did not pursue the matter further. The revenue did not examine the source of income of the said alleged creditors to find out whether they were credit-worthy or were such who could advance the alleged loans. There was no effort made to pursue the so-called alleged creditors. In those circumstances, the assessee could not do any further. In the premises, if the Tribunal came to the conclusion that the assessee has discharged the burden that lay on him then it could not be said that such a conclusion was unreasonable or perverse or based on no evidence. If the conclusion is based on some evidence on which a conclusion could be arrived at, no question of law as such arises….”
It was further submitted that the fact that the residence of the parties to whom supervision charges were paid were at a distance or that ladies and old persons were involved in supervision cannot be basis to consider the supervision charges to be non-genuine. These persons entered into the contract with the assessee firm for providing supervision. It was not the condition of the contract and which never remains so that the services will be provided by these persons themselves personally. It was for these persons to organize their
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business affairs properly by engaging proper people. Even the distance cannot in any way be a factor as even the assessee’s office was situated in Mansarover, Jaipur whereas larger operations were carried out in Jhunjhunu.
It was further submitted that supervision charges were even paid in the immediately preceding year i.e. AY 2012-13 by the assessee firm and no additions were made in this regard by the ld. AO. The ld. CIT(A) is not correct in contending that books of accounts of assessee firm were rejected and GP was estimated. In this regard it is submitted that the books were rejected by the ld. AO on all together a different footing that certain expenses were paid in cash and were not supported by proper vouchers. Ld. AO has nowhere, in the said order, doubted with regard to the genuineness of the supervision charges which in the said year, as in the current year, were paid through proper banking channel.
It was further submitted that the Hon’ble Supreme Court in the case of Radhasoami Satsang [1992] 193 ITR 321 (SC) held that “…… We are aware of the fact that strictly speaking res judicata does not apply to income-tax proceedings. Again, each assessment year being a unit, what is decided in one year may not apply in the following year but where a fundamental aspect permeating through the different assessment years has been found as a fact one way or the other and parties have allowed that position to be sustained by not challenging the order, it would not be at all appropriate to allow the position to be changed in a subsequent year…..”
It was further submitted that none of the parties, to whom supervision charges have been paid, are related parties covered under section
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40A(2)(b). It was also submitted that when supervision charges paid to two parties has been allowed, there remains no reason why such charges paid to the remaining parties, under the same set of facts, should be disallowed.
On the other hand, ld. D/R supported the orders of the
authorities below.
We have heard the rival contentions and perused the material available on record. The issue under consideration relates to allowance of supervision charges as an allowable expenditure in the hands of the assessee firm. Where the said expenditure is called for examination by the AO during the course of assessment proceedings, the primary onus is on the assessee firm wherein it has to demonstrate how the same is allowable for computing its taxable income. In other words, the assessee has to demonstrate that the said expenditure has been incurred wholly and exclusively for the purposes of its business. For the purposes, the assessee firm has to demonstrate through verifiable evidence the nature of such supervision services, how such services are relevant or necessitated for carrying out its business activities, the terms and conditions agreed for carrying out such supervision, the actual availment of such supervision services, etc. However, we find that the assessee firm has not brought on record any evidence through which it can be verified that such supervision services have been rendered or availed by the assessee firm. It is no doubt true that the payments have been made to these entities during the year and these entities have also filed the confirmations of receipt of such charges, however, the fact of payment is ancillary and secondary to the
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rendering of services or availment of supervision services and cannot be a basis to hold that since the payment have been made, the services ought to have been rendered or availed by the assessee firm. The payment is the consideration towards the discharge of consideration for rendering of services and unless such rendering of services is not proved, as in the instant case, mere payment is not sufficient enough to hold that the expenditure has been incurred and allowable in the hands of the assessee firm. Further, it is not a case that the AO has not taken any action to verify the transaction. He has issued notices under section 133(6) and when he was not convinced with the replies, he also issued summons under section 131 as well which remain uncomplied with and which has put further question mark on the authencity of the transaction under consideration. We have also gone through the assessment order passed under section 143(3) for AY 2012-13 wherein the AO noticed that various expenses such as carriage inwards, diesel and oil expenses, loading charges, supervision charges and unloading charges were made in cash and no supporting evidence has been maintained and were not verifiable and the AO has thus rejected the books of accounts u/s 145(3) of the Act and has made lump sum trading addition thereof. Hence, it cannot be said that the supervision charges were allowed by the AO for the AY 2012-13.
Further, we have gone through the findings of the ld CIT(A) and in light of the above discussions, we donot see any infirmity in the same and the said findings are hereby affirmed which are reproduced as under:
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“(iv) I have duly considered the submission of the appellant, assessment order and the material placed on record. It is a matter of fact that the iron sorting work of the appellant was carried out at the mines at Khetri, Jhunjhunu, which is at a distance of 155 Kms from the city of Jaipur where these entities reside. These five entities do not appear before the AO in response to summon issued u/s 131 of the Act. In fact, before of issue of summon u/s 131 of the Act, vide order sheet entry dated 21.12.2015, the AO required the AR of the appellant to produce Ms. Renu Nathawal and Ms. Sushil Kanwar, but they were not produced before the AO. (v) During the appellate proceedings, the AR was required to furnish documentary evidence for receiving supervision services and it was submitted that no formal documentation in this regard is available with the appellant firm as in small unorganized business entities, formal evidences are not obtained, as the business transaction remain under direct management and control of the owners. Moreover, the nature of services received were such for which, otherwise also, formal documentation is not possible. The services were rendered by the individuals themselves and in case of HUF, by the respective kartas. Thus, the appellant has failed to brought on record any documentary evidence which may even suggest that supervision work at the sites were carried out by them. It cannot be believed that in the process of supervision work, no documentary evidence was created on day to day basis, if genuine supervision work has done. It may be mentioned that the burden is on the appellant to
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substantiate its claim of supervision expenses, which it failed miserable not only at the assessment stage but also at the appellate stage. In fact, the appellant has not even elaborated what was the exact nature of work done, whether the ladies and the old man (Shri Sukhmal Kumar Jain – aged 71 years) were capable of doing that work, especially in view of the fact that the site is situated more than 155 kms. from the residence of these entities. (vi) It was the contention of the appellant that similar supervision expenses were allowed in its assessment order for the AY 2012- 13. It may be mentioned that as per the said assessment order, the AO noted that various expenses including supervision charges were not verifiable and the AO has rejected the books of accounts of the appellant u/s 145(3) of the Act and has made lump sum trading addition thereof. Hence, it cannot be said that the supervision charges were allowed by the AO for the AY 2012- 13. Thus, thus contention of the appellant deserves to be rejected. (vii) Therefore, in view of the above discussion and looking to the totality of facts and circumstances of the instant case under consideration, it is held that the AO was justified in disallowing supervision charges of Rs. 30 lac and hence the same is hereby sustained.”
In the result, disallowance of supervision charges of Rs. 30 lac is hereby sustained and ground no. 2 of assessee’s appeal is dismissed.
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In the result, the appeal of the assessee is dismissed.
Order pronounced in the open court on 08/12/2017.
Sd/- Sd/- ¼fot; ikWy jko½ ¼foØe flag ;kno½ (Vijay Pal Rao) (Vikram Singh Yadav) U;kf;d lnL;@Judicial Member ys[kk lnL;@Accountant Member Tk;iqj@Jaipur fnukad@Dated:- 08/12/2017. *Ganesh Kr. आदेश की प्रतिलिपि अग्रेf’ात@ब्वचल वf जीम वतकमत वितूंतकमक जवरू 1. vihykFkhZ@The Appellant- G.D.Minerals, Jaipur 2. izR;FkhZ@ The Respondent- ACIT, Circle-1, Jaipur 3. vk;dj vk;qDr@ CIT 4. vk;dj vk;qDr@ CIT(A) 5. विभागीय प्रतिनिधि] आयकर अपीलीय अधिकरण] जयपुर@क्त्ए प्ज्Aज्ए Jंपचनत. 6. xkMZ QkbZy@ Guard File { ITA No. 13/JP/2017} vkns'kkuqlkj@ By order, सहायक पंजीकार@Aेेज. त्महपेजतंत