CLASSIC STRIPES P.LTD,MUMBAI vs. DCIT 6(2), MUMBAI

आदेश / O R D E R PER M. BALAGANESH (A.M): This appeal in ITA No.2378/Mum/2017 for A.Y.2010-11 arises out of the order by the ld. Commissioner of Income Tax (Appeals)-12, Mumbai in appeal No.CIT(A)-12/DCIT-6(2)(1)/93/13-14 dated 30/04/2013 (ld. CIT(A) in short) against the order of assessment passed u/s.143(3)of the Income Tax Act, 1961 (hereinafter referred to as Act) dated 15/03/2013 by the ld. Dy. Commissioner of Income Tax, Circle- 6(2),Mumbai (hereinafter referred to as ld. AO).

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shares issued and allotted). This is as per para 6.1 of the scheme of merger, which has been duly approved by the Hon'ble Bombay High Court. Since on merger, the book value of net assets of Safety Products Division was less than the face value of equity shares issued, the difference was debited to Goodwill Account to the tune of Rs. 18,26,89,529/-.

3.1. The ld. AO has noted in the assessment order that the assessee has not claimed the deduction of depreciation in the original return of income but claimed it by way of revised computation of income filed during assessment proceedings. He observed that any claim of deduction has to be made at the time of filing the return of income and that no fresh claim could be entertained at the stage of assessment. The ld. AO further noted that Safety Division of M/s Forma Sports Pvt Ltd is a consistent loss making division. Goodwill means reputation of the business and it is not clear as to how a consistent loss making division will bring advantage of reputation and brand to the business of the assessee. Accordingly, he concluded that this goodwill is a self generated goodwill. The ld. AO relied on the decision of co-ordinate bench decision of Jaipur Tribunal in the case of M/s Jaypore Sugar Company Limited, reported in 44 SOT 625 and noted that the assessee's case is squarely covered in the above cited decision in favour of the revenue. The ld. AO noted that the assessee has accrued the commercial benefit and does not have a commercial right. In view of this, the ld. AO did not agree to the claim of depreciation on goodwill on merits.

3.2. The ld. CIT(A) confirmed the disallowance of depreciation on goodwill arising in the case of the assessee by observing that the goodwill arose on account of market value of immovable assets which were higher

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than their book value, whereas, as per the order of the Hon’ble Bombay High Court sanctioning the scheme of merger, goodwill shall be recorded on account of difference on book value on net assets taken over and face value of equity shares issued as allotted. The ld. CIT(A) reproduced 6.1 to 6.3 of the order of the Hon’ble Bombay High Court sanctioning the claim of merger which reads as under:-

" 6.1 CSL shall upon the arrangement becoming effective, record the assets and liabilities of the safety Products Division of FSPL vested in it pursuant to this scheme, at the respective book values, ignoring revaluation, if any as appearing in the books of FSPL at the close of business of the day immediately preceding the Appointed date. 6.2. CSL shall credit to the share Capital Account in its books of account, the aggregate face value of the equity shares of CSL issued and allotted by it to the equity shareholders of FSPL pursuant to this Scheme. 6.3. The different between the book value of net assets of Safety Products Division of FSPL and the face value of equity shares and allotted shall be credited by CSL to the General Reserve Account or debited to the Goodwill Account, as the case may be.”

3.3. The ld. CIT(A) observed that there was no transfer of intangible assets from the Safety Division of Forma Sports Pvt. Ltd. to the assessee. The transfer is of only movable and immovable assets. Further, the Hon’ble High Court’s order is that the assessee shall record the goodwill on account of difference of book value of net assets of Safety Products division of FSPL and face value of equity shares issued and allotted. Further, the assets and liabilities shall be recorded at book value by ignoring revaluation. This clearly indicates that the assessee has to record the goodwill of the basis of book value of the net assets of Safety division

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of FSPL. This type of goodwill is not approved by the Hon’ble Mumbai High Court in the scheme of arrangement of between these parties. Further, the case laws relied on by the assessee are in the case where goodwill is accounted on account of excess consideration paid by the assessee over the value of net assets acquired. But, in the instant case, the goodwill arose on account of market value of assets acquired from the Safety division of FSPL. With the aforesaid observations, the ld. CIT(A) upheld the action of the ld. AO in disallowing the depreciation claimed on goodwill. 4. We have heard rival submissions and perused the materials available on record. At the outset, we find that the goodwill in the instant case arose on account of merger of Safety Products Division of FSPL with the assessee company. It is not in dispute that the said merger was duly approved by the Hon’ble Bombay High Court vide order dated 22/01/2010. Pursuant to the said merger, the assets and liabilities that were recorded in the books of FSPL got vested / transferred to the books of the assessee company at their respective book values. We find from the journal entries passed in the books of FSPL prior to merger, post merger and entries passed in the books of assessee which are enclosed in page 10 of the paper book filed along with written submissions, that the assessee had recorded the value of assets and liabilities only at their respective book values i.e. the values that were recorded in the books of

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FSPL were taken in the books of assessee company pursuant to merger. The excess of liabilities over net assets was treated as goodwill and the depreciation for the same was claimed by the assessee treating the said goodwill as an intangible asset. We find that the ld. AO had observed that there is no question of any goodwill prevailing in the books of FSPL in view of the fact that, it had incurred losses. This observation of the ld. AO, in our considered opinion, is not tenable in view of the fact that whether the unit is incurring losses or not, has got nothing to do with the existence of goodwill prevailing in the said unit. Goodwill would arise on account of various factors such as continuing clients, continuing business relationship, established set up for smooth conduct of business, continuing business, commercial and industrial rights and licenses to the successor company / merged entity. These commercial, business and industrial rights were duly acquired by the assessee company through a scheme of merger and due consideration passed on for the same by way of allotment of shares. Hence, the same would factually tantamount to acquisition of goodwill. Since, the goodwill is an intangible asset, within the meaning of Section 32 of the Act in the form of industrial, business and commercial rights, the assessee would be eligible for depreciation u/s.32 of the Act. We find that the ld. CIT(A) had observed that goodwill in the instant case had arose on revaluation of properties which is factually incorrect as observed hereinabove by us i.e the value of assets

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and liabilities were recorded at book values only pursuant to merger. We find that lower authorities had placed reliance on the decision of Co- ordinate Bench of Jaipur Tribunal in the case of Jaypore Sugar Co.Ltd., reported in 44 SOT 625 to support their proposition. We find that subsequent to this decision, the Hon’ble Supreme Court in the case of CIT vs. Smifs Securities Ltd., reported in 348 ITR 302(SC) vide order dated 22/08/2012 had specifically held that goodwill arising on account of amalgamation would constitute intangible asset eligible for depreciation u/s.32 of the Act. We find that the issue before the Hon’ble Supreme Court was whether goodwill is an asset within the meaning of Section 32 of the Act and whether depreciation thereon, is allowable under that Section. The Hon’ble Apex Court decided this question in favour of the assessee by holding as under:-

“In the present case, the assessee had claimed deduction of Rs. 54,85,430/- as depreciation on goodwill. In the course of hearing, the explanation regarding origin of such goodwill was given as under: "In accordance with Scheme of Amalgamation of YSN Shares & Securities (P) Ltd with Smifs Securities Ltd (duly sanctioned by Hon'ble High Courts of Bombay and Calcutta) with retrospective effect from 1st April, 1998, assets and liabilities of YSN Shares & Securities (P) Ltd were transferred to and vest in the company. In the process goodwill has arisen in the books of the company." 2. It was further explained that excess consideration paid by the assessee over the value of net assets acquired of YSN Shares and Securities Private Limited [Amalgamating Company] should be considered as goodwill arising on amalgamation. It was claimed that the extra consideration was paid towards the reputation which the

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Amalgamating Company was enjoying in order to retain its existing clientele. 3. The Assessing Officer held that goodwill was not an asset falling under Explanation 3 to Section 32(1) of the Income Tax Act, 1961 ['Act', for short]. We quote hereinbelow Explanation 3 to Section 32(1) of the Act: "Explanation 3.-- For the purposes of this sub-section, the expressions 'assets' and 'block of assets' shall mean-- [a] tangible assets, being buildings, machinery, plant or furniture; [b] intangible assets, being know-how, patents, copyrights, trademarks, licences, franchises or any other business or commercial rights of similar nature." 4. Explanation 3 states that the expression 'asset' shall mean an intangible asset, being know-how, patents, copyrights, trademarks, licences, franchises or any other business or commercial rights of similar nature. A reading the words 'any other business or commercial rights of similar nature' in clause (b) of Explanation 3 indicates that goodwill would fall under the expression 'any other business or commercial right of a similar nature'. The principle of ejusdem generis would strictly apply while interpreting the said expression which finds place in Explanation 3(b). 5. In the circumstances, we are of the view that 'Goodwill' is an asset under Explanation 3(b) to Section 32(1) of the Act. 6. One more aspect needs to be highlighted. In the present case, the Assessing Officer, as a matter of fact, came to the conclusion that no amount was actually paid on account of goodwill. This is a factual finding. The Commissioner of Income Tax (Appeals) ['CIT(A)', for short] has come to the conclusion that the authorised representatives had filed copies of the Orders of the High Court ordering amalgamation of the above two Companies; that the assets and liabilities of M/s. YSN Shares and Securities Private Limited were transferred to the assessee for a consideration; that the difference between the cost of an asset and the amount paid constituted goodwill and that the assessee-Company in the process of amalgamation had acquired a capital right in the form of goodwill because of which the market worth of the assessee-Company stood increased. This finding has also been upheld by Income Tax Appellate Tribunal ['ITAT', for short]. We see no reason to interfere with the factual finding. 7. One more aspect which needs to be mentioned is that, against the decision of ITAT, the Revenue had preferred an appeal to the High Court in which it had raised only the question as to whether goodwill is an asset under Section 32 of the Act. In the circumstances, before the

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High Court, the Revenue did not file an appeal on the finding of fact referred to hereinabove. 8. For the afore-stated reasons, we answer Question No.[b] also in favour of the assessee.”

4.1. Respectfully following the aforesaid Supreme Court decision, we hold that assessee is entitled for depreciation of Rs.4,56,72,382/- claimed @25% on goodwill valued at Rs.18,26,89,529/-.

4.2. Yet another issue involved in this appeal is that assessee had not claimed its depreciation on goodwill in the return filed by it. However, during the course of assessment proceedings, based on the advice of Tax Consultant and based on the decision of Hon’ble Supreme Court referred to supra, the assessee claimed depreciation on goodwill by way of filing revised computation of income before the ld. AO as the time limit for filing revised return had expired. We find that the ld. AO had ignored the said revised computation by observing that any valid claim could be entertained only if it is claimed in the return of income. We find this action was upheld by the ld. CIT(A). In this regard, we find that the Co- ordinate Bench of Ahmedabad Tribunal had an occasion to address this very same issue in the case of CIT vs Zydus Wellness Ltd., reported in 162 ITD 604 wherein, by placing reliance on the decision of Hon’ble Bombay High Court in the case of CIT vs. Pruthvi Brokers and

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Shareholders Pvt. Ltd., reported in 349 ITR 336, the Tribunal held as under:-

“34. We observe that pursuant to the scheme of arrangement approved by Hon. Gujarat High Court in Asst. Year 2008-09 i.e. Zydus Wellness Ltd. acquired the Consumer Products Division of Cadila Healthcare Ltd. including the Brands 'Sugar-free' and 'Ever Youth' and related intangible assets of the said business, which came to be accounted for as "Goodwill" in the books of accounts of Zydus Wellness Ltd. The value of the said Goodwill, acquired at Rs.28.76 crores, stood duly reflected in the Annual Accounts of the Company for F.Y.2008-09 as the excess of the agreegate face value of the Equity Shares issued over the excess of the Assets and Liabilities. At the time of filing of return income in Asst. Year 2010-11 the issue of claiming of depreciation on goodwill was debatable and uncertain. It was only after the judgment of Hon. Supreme Court in the case of CIT vs. Smiffs Securities Ltd. (supra) wherein Hon. Court had an occasion to deal with the issue of claiming depreciation on goodwill, similar to the case of assessee wherein goodwill was paid on account of amalgamation. Hon. Court held as under :- "Explanation 3 states that the expression 'asset' shall mean an intangible asset, being know-how, patents, copyrights, trademarks, licences, franchises or any other business or commercial rights of similar nature. A reading the words 'any other business or commercial rights of similar nature' in clause (b) of Explanation 3 indicates that goodwill would fall under the expression 'any other business or commercial right of a similar nature'. The principle of ejusdem generis would strictly apply while interpreting the said expression which finds place in Explanation 3(b). In the circumstances, we are of the view that 'Goodwill' is an asset under Explanation 3(b) to Section 32(1) of the Act. " 35. Subsequent to the pronouncement of the judgment of Hon. Apex Court in the case of CIT vs. Smiffs Securities Ltd. (supra) Asst. Year 2010-11 assessee put forward its rightful claim for depreciation of Rs.7,19,01,743/- being 25% value of assets of Rs.28.76 crores. Assessee's claim of depreciation on goodwill was denied by ld. Assessing Officer, however, ld. CIT(A) allowed assessee's claim by following the judgment of Hon. Apex Court in the case of CIT vs. Smifs Securities Ltd. (supra). 36. Further, we also observe that the main reason for denial of deduction by ld. Assessing Officer was that assessee has not filed revised return of income to make rightful claim. Ld. AR took us through the judgment of Hon. Bombay High Court in the case of CIT vs. Pruthvi Brokers and Shareholders 349 ITR 336 (Bom) wherein it has been categorically held that Assessing Officer is bound to entertain rightful claim of deduction

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made otherwise than by filing revised return. We find it pertinent to observe the ratio of the judgment of Hon. Bombay High Court in the case of CIT vs. Pruthvi Brokers and Shareholders (supra) wherein following observation was made :- "A long line of authorities establish clearly that an assessee is entitled toraise additional grounds not merely in terms of legal submissions, but also additional claims not made in the return filed by it. [Para 10] In Jute Corpn. of India Ltd. [1991] 187 ITR 688 for the assessment year 1974-75 the appellant did not claim any deduction of its liability towards purchase tax under the provisions of the Bengal Raw Jute Taxation Act, 1941, as it entertained a belief that it was not liable to pay purchase tax under that Act. Subsequently, the appellant was assessed to purchase tax and the order of assessment was received by it on 23rd November, 1973. The appellant challenged the same and obtained a stay order. The appellant also filed an appeal from the assessment order under the Income Tax Act. It was only during the hearing of the appeal that the assessee claimed an additional deduction in respect of its liability to purchase tax. The Appellate Assistant Commissioner (AAC) permitted it to raise the claim and allowed the deduction. The Tribunal held that the AAC had no jurisdiction to entertain the additional ground or to grant relief on a ground which had not been raised before the Income Tax Officer. The Tribunal also refused the appellant's application for making a reference to the High Court. The High Court upheld the decision of the Tribunal and refused to call for a statement of case. It is in these circumstances that the appellant filed the appeal before the Supreme Court. The Supreme Court held as under:- "5. In CIT v. Kanpur Coal Syndicate, a three Judge bench of this Court discussed the scope of Section 31(3)(a) of the Income Tax Act, :1922 which is almost identical to Section 251(l)(a). The court held - asunder: (ITR p. 229) "If an appeal lies, Section 31 of the Act describes the powers of the Appellate Assistant Commissioner in such an appeal. Under Section 31(3)(a) in disposing of such an appeal the Appellate Assistant Commissioner may, in the case of an order of assessment, confirm, reduce, enhance or annul the assessment; under clause (b) thereof he may set aside the assessment and direct the Income Tax Officer to, make a fresh assessment. The Appellate Assistant Commissioner has, therefore, plenary powers in disposing of an appeal. The scope of his power is co-terminus with that of the Income-tax Officer. He can do what the Income-tax Officer can do and also direct him to do what he has failed to do," 6. The above observations are squarely applicable to the interpretation of Section 251(l)(a) of the Act. The declaration of law is clear that the power of the Appellate Assistant Commissioner is co-terminus with that of the Income Tax Officer, if that be so, there appears to be no reason as to why the appellate authority cannot modify the assessment order on an

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additional ground even if not raised before the Income Tax Officer. No exception could be taken to this view as the Act does not place any restriction or limitation on the exercise of appellate power. Even otherwise an Appellate Authority while hearing appeal against the order of a subordinate authority has all the powers which the original authority may have in deciding the question before it subject to the restrictions or limitations if any prescribed by the statutory provisions. In the absence of any statutory provision the Appellate Authority is vested with all the plenary powers which the subordinate authority may have in the matter. There appears to be no good reason and none was placed before us to justify curtailment of the power of the Appellate Assistant Commissioner in entertaining an additional ground raised by the assessee in seeking modification of the order of ' assessment passed by the Income Tax Officer." ' Asst. Year 2010-11 (B) It is clear, therefore, that an assessee is entitled to raise not merely additional legal submissions before the appellate authorities, but is also entitled to raise additional claims before them. The appellate authorities have the discretion whether or not to permit such additional claims to be raised. It cannot, however, be said that they have no jurisdiction to consider the same. They have the jurisdiction to entertain the new claim. That they may choose not to exercise their jurisdiction in a given case is another matter. The exercise of discretion is entirely different from the existence of jurisdiction. [Para 11] Further the observation of the Supreme Court in the case of Jute Corpn. of India Ltd. (supra) to the effect 'if the ground so raised could not have been raised at that particular stage when the return was filed or when the : assessment order was made....' or 'that the ground became available on account of change of circumstances or law,' does not curtail the ambit of the jurisdiction of the appellate authorities stipulated earlier. They do not restrict the new/additional grounds that may be taken by the assessee before the appellate authorities to those that were not available when the return was filed or even when the assessment order was made. The appellate authorities, therefore, have jurisdiction to deal not merely with additional grounds, which became available on account of change of circumstances or law, but with additional grounds which were available when the return was filed. The first part viz., 'if the ground so raised could not have been raised at that particular stage when the return was filed or when the assessment order was made....' clearly relate to cases where the ground was available when the return was filed and the assessment order was made but 'could not have been raised' at this stage. The words are 'could not have been raised' and not 'were not in existence'. Grounds which were not in existence when the return was filed or when the assessment order was made fall within the second category viz., where 'the ground became available on account of change of 'circumstances or law.'[Paras 12 and 13] : It was then submitted by Mr. Gupta that the Supreme Court had taken a different view in Goetze (India) Ltd (supra). We are unable to agree. The decision was rendered by a Bench of two learned Judges and expressly refers to the judgment of the Bench of three learned Judges in National

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Thermal Power Comp. Ltd. (supra). The question before the Court was whether the appellant-assessee could make a claim for deduction, other than by filing a revised return. After the return was filed, the appellant sought to claim a deduction by way of a letter before the Assessing Officer. The claim, therefore, was not before the appellate authorities. The deduction was disallowed by the Assessing Officer on the ground that there was no provision under the Act to make an amendment in the return of income by modifying an application at the assessment stage without revising the return. The Commissioner of Income-tax (Appeals) allowed the assessee's appeal. The Tribunal, however, allowed the department's appeal. In the Supreme Court, the assessee relied upon the judgment in National Thermal Power Co. Ltd. (supra) contending that it was open to the assessee to raise the points of law even before the Tribunal. The Supreme Court held:- "4. The decision in question is that the power of the Tribunal under section 254 of the Income-tax Act, 1961, is to entertain for the first time a point of law provided the fact on the basis of which the issue of law can be raised before the Tribunal. The decision does not in any way relate to the power of the Assessing Officer to entertain a claim for deduction otherwise than by filing a revised return. In the circumstances of the case, we dismiss the civil appeal. However, we make it clear that the issue in this case is limited to the power of the assessing authority and does not impinge on the power of the Income-tax Appellate Tribunal under section 254 of the Income-tax Act, 1961. There shall be no order as to costs." (Para 22) It is clear to us that the Supreme Court did not hold anything contrary to what was held in the previous judgments to the effect that even if a claim is not made before the assessing officer, it can be made before the appellate authorities. The jurisdiction of the appellate authorities to entertain such a claim has not been negated by the Supreme Court in this judgment. (Para -: 23)" The Appellant, therefore, prays that in any case, your Honour, as the first appellate authority is empowered to entertain the Appellant's claim for Depreciation on Goodwill, respectfully following the ratio of the Apex Court in the case of Smijfs Securities (supra)." 37. Respectfully following the judgment of Hon. Apex Court in the case of CIT vs. Smiffs Securities Ltd. (supra), and the judgment of Hon. Bombay High Court in the case of CIT vs. Pruthvi Brokers and Shareholders (supra) we are of the view that ld. CIT(A) has rightly allowed the justifiable & correct claim of depreciation on 'goodwill' made by the assessee through revised computation of income without filing revised return of income during the course of assessment proceedings. Therefore, no interference is called for in the order of ld. CIT(A) on this issue. This ground of Revenue is dismissed.”

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4.3. Respectfully following the aforesaid decision, the grounds raised by the assessee with regard to claim of depreciation on goodwill are allowed. Needless to mention that the assessee would be entitled for this depreciation year on year on recurring basis on the written down value of each year.

5.1. We have heard rival submissions and perused the materials available on record. We find that assessee had made purchase of capital goods amounting to Rs.43,94,251/- from M/s. Deep Enterprises and Mahabir Enterprises. The assessee provided the copies of invoices, delivery challans and bank statements during the course of assessment proceedings. The items purchased were aluminium frames which were regularly required for fixing the screen printing cloth to print the self adhesive films. The ld. AO observed that the aforesaid two suppliers i.e., M/s. Deep Enterprises and M/s. Mahabir Enterprises names appeared in the list of suspicious parties in the website of Sales Tax department of Govt. of Maharashtra classifying them as hawala dealers. The ld. AO

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sought to make verification of the veracity of those suppliers. For this purpose, he directed the assessee to purchase the parties before him for examination. Since, there was a lapse of three years from the time of transaction that took place between the assessee and those suppliers, the assessee could not produce those parties in person before the ld. AO. The assessee submitted that it had made purchases of capital goods of Rs.14 Crores and consumables of Rs.80 Crores during the year under consideration and it was practically impossible for them to keep track of all the parties from whom the goods were purchased. It was submitted that once the goods are delivered by the concerned suppliers and payments made to them, the assessee cannot be expected to keep track of all the suppliers that too, after a lapse of three years from the date of transaction.

5.2. The assessee submitted that from the bank statement of the assessee which was submitted before the ld. AO, it could be seen that the payments were made to the suppliers by crossed account payee cheques. The assessee also submitted the copy of ledger account of M/s. Deep Enterprises and Mahabir Enterprises as appearing in its books. We find that the aluminium frames that were purchased were duly utilized in the business of the assessee and finished product generated thereon, had been sold and hence, duly reported by the assessee. Hence, there cannot

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be any dispute on the same. However, the assessee was not able to prove beyond doubt, the suspicion that arose in the minds of the revenue in respect of these parties appearing to be in the negative list of sales tax department of Government of Maharashtra. In these circumstances, it could be safely concluded that assessee could have purchased these capital goods amounting to Rs.43,94,251/- from the grey market in order to save the liability of VAT. Since the items purchased were capital goods, which is not in dispute, hence, we hold that the depreciation attributable to that VAT portion alone should be disallowed in the hands of the assessee. Needless to mention that assessee could be entitled for depreciation on these capital assets on recurring basis year on year on the basis of return down value of each year. Accordingly, grounds raised by the assessee in this regard are partly allowed. 6. In the result, appeal of the assessee is partly allowed.

Order pronounced on 07/08/2020 by way of proper mentioning in the notice board.

Sd/- Sd/- (RAVISH SOOD) (M.BALAGANESH) JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai; Dated 07/08/2020 KARUNA, sr.ps

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Copy of the Order forwarded to : The Appellant 1. The Respondent. 2. The CIT(A), Mumbai. 3. CIT 4. DR, ITAT, Mumbai 5. Guard file. 6. //True Copy//

BY ORDER,

(Asstt. Registrar) ITAT, Mumbai