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Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE
Before: SHRI S.S. GODARA & DR. DIPAK P. RIPOTE
IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI S.S. GODARA, JUDICIAL MEMBER AND DR. DIPAK P. RIPOTE, ACCOUNTANT MEMBER ITA No.472/PUN/2020 निर्धारण वषा / Assessment Year : 2015-16 Bank of Maharashtra Vs. DCIT, Circle 1501, Lokmangal, Shivajinagar, 1(1), Pune Pune – 411005 PAN : AACCB0774B Appellant Respondent
ITA No.596/PUN/2020 निर्धारण वषा / Assessment Year : 2015-16 DCIT, Circle Vs. Bank of Maharashtra 1(1), Pune 1501, Lokmangal, Shivajinagar, Pune – 411005 PAN : AACCB0774B Appellant Respondent
Assessee by Shri S. Ananthan & Mrs. Lalitha R. Revenue by Shri Rajeev Kumar Date of hearing 27-06-2022 Date of pronouncement 30-06-2022 आदेश / ORDER PER S.S. GODARA, JM : These assessee‟s and Revenue‟s cross appeals for AY 2015-16 arise against the CIT(A)-1, Pune‟s order dated 23-03-2020 passed in case No.PN/CIT(A)-1/DCIT Cir-1(1)/Pn/243/17-18/44 in proceedings under Section 143(3) of the Income Tax Act, 1961, in short „the Act‟. Heard both the parties. Case files perused.
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We come to the assessee‟s appeal in ITA No.472/PUN/2020 raising the following substantive grounds: “1. The order of the learned CIT(A) is bad in law, arbitrary, perverse and legally unsustainable. 2. In the facts and circumstances of the case and in law, the learned CIT(A) has erred in restricting the claim made by the appellant u/s 36(1)(viia) of the Act to Rs. 143,07,19,755/- as against the claim of Rs. 1083,06,95,013/- made by the appellant. 2.1. The learned CIT(A) erred in holding that the deduction should be restricted to the provision made in the books accounts for rural advances. 2.2. The learned CIT(A) failed to appreciate that in order to claim deduction u/s 36(1 )(viia), there is no requirement u/s 36(1)(viia) that the provision should relate to rural advances. 2.3. The learned CIT(A) failed to appreciate the fact the entire provision made has to be considered and not the provision relating to rural advances only be considered. 2.4. The learned CIT(A) failed to appreciate the fact that the Hon'ble Supreme Court in the case of Catholic Syrian Bank [2012] 343 ITR 270 (SC) did not lay down the law that the deduction should be allowed by only considering the provision for rural advances in the books. 2.5. The learned CIT(A) erred in not following the order of the Hon'ble ITAT in the app Bank's own case for the earlier Assessment years. 3. In the facts and circumstances of the case and in law, the learned CIT(A) has erred in confirming the disallowance of prior period expenses amounting to Rs. 1,72,73,670/-. 3.1. The learned CIT(A) failed to appreciate the fact that the expenses were crystallized during the previous year relevant to the assessment year under appeal. 3.2. Without prejudice to the above, if this expenditure is not allowable during the Assessment Year 2015-16, the learned Assessing Officer be directed to allow the same as an expenditure for the Assessment Year 2014-15. 4. In the facts and circumstances of the case and in law, the learned CIT(A) has erred in confirming the disallowance of the interest paid amounting to Rs. 1,71,338/- for delayed remittance of TDS. 4.1. The learned CIT(A) failed to appreciate that interest on delayed remittance of TDS would be allowable under Section 37 of the Act.
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In the facts and circumstances of the case and in law, the appellant be allowed a claim towards education cess & secondary & higher education cess amounting to Rs.8,69,48 904/- paid by it during the previous year 2014-15 in the computation of total income. 6. In the facts and circumstances of the case and in law, the action of the learned CIT(A) in holding that the provisions of Section 115JB are applicable to the appellant bank being bad in law, arbitrary, perverse and legally unsustainable the same may please be deleted. 6.1. The learned CIT(A) failed to appreciate the fact that the provisions of Section 115JB are not applicable to the appellant. 6.2 Without prejudice to the above, the learned CIT(A) failed to appreciate the fact that even if the provisions of section 115JB are applicable, the computation fails and as such, book profit cannot be computed as per section 115JB. 7. Without prejudice to Ground No. 6, the learned CIT(A) erred in adding various items to the book profit which are beyond the scope of the Section 115JB. 7.1 The learned CIT(A) erred in holding that AO is not supposed to examine the nature of item as to whether it is provision or write off while computing the book profit. 7.2 The learned CIT(A) failed to appreciate the fact that the various items added to the book profit are not covered by the Explanation to Section 115JB.
We note at the outset that there is hardly any need for us to delve deeper in the assessee‟s first and foremost substantive ground challenging section 36(1)(viia) disallowance pertaining to bad and doubtful debts as the same is found to be a recurring issue between the parties. This tribunal‟s latest co-ordinate bench order in assessment year 2010-11 appears to have restored the instant issue to the assessing authority as follows: “3.3 Both sides heard. Orders of the authorities below perused. In ground No. 1 of appeal the assessee has assailed the findings of Commissioner of Income Tax (Appeals) in disallowing assessee’s claim u/s. 36(1)(vii) of the Act on account of write off of debts by non rural branches of assessee Bank. We observe that identical issue
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had come up before the Tribunal in assessee’s own case in ITA No. 1505/PN/2008 and in ITA Nos. 1135 to 1138/PN/2013 (supra). The relevant extract of the findings of Co-ordinate Bench on the issue are reproduced here-in-under : “28. By way of Ground of Appeal No.3, assessee has raised a claim of deduction of Rs.68,06,15,000/- u/s 36(1)(vii) of the Act on account of write off on debts by the non-rural branches of the assessee bank. The learned counsel for the assessee explained that the said claim was raised by way of an Additional Ground of Appeal before the CIT(A) vide letter dated 26.08.2008 but the same has not been inadvertently considered by the CIT(A). In this connection, a reference has been invited to a copy of the communication addressed to the CIT(A), which is placed in the Paper Book. Before us, it is sought to be canvassed that the said claim is covered by the judgement of the Hon’ble High Court in the case of Catholic Syrian Bank Ltd. vs. CIT, (2012) 343 ITR 270 (SC) and in the case of assessee for assessment years 2002-03, 2003- 04 and 2004-05 the Tribunal vide its order dated 30.05.2014 (supra) admitted such an Additional Ground but remitted the same back to the file of the Assessing Officer for adjudication in the light of the Hon’ble Supreme Court in the case of Catholic Syrian Bank Ltd. (supra). The aforesaid factual matrix has not been disputed by the learned CIT-DR appearing for the Revenue. As a result, following the precedent in the assessee’s own case, we deem it fit and proper to direct the Assessing Officer to consider the said claim of the assessee in the light of the judgement of the Hon’ble Supreme Court in the case of Catholic Syrian Bank Ltd. (supra). Needless to say, the Assessing Officer shall allow the assessee a reasonable opportunity to put-forth its claim and only thereafter he shall proceed to adjudicate the claim of the assessee as per law. Thus, on this Ground assessee succeeds for statistical purposes.” 3.4 Since, the issue in present appeal is identical to the one already considered by the Co-ordinate Bench in assessee’s own case and there has been no change in the facts, we deem it appropriate to restore the issue to Assessing Officer for re- adjudication with similar directions. The ground No. 1 of the appeal is allowed for statistical purpose in the same terms.”
This clinching fact has gone unrebutted from the Revenue side about learned co-ordinate bench having already adjudicated the instant issue in favour of the assessee. We, therefore, accept the assessee‟s instant first and foremost substantive grievance for statistical purposes in very terms and leave open for the Assessing Officer to frame his consequential adjudication.
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Next comes the second issue of disallowance of prior period expenditure amounting to Rs.1,72,73,670/- made in both the lower proceedings. Suffice to say, both the learned lower authorities are of the view that once the assessee follows mercantile system of accounting, it ought to have claimed and recognized the impugned expenditure in the year of accrual than that of the actual expenditure. The assessee‟s case on the other hand is the impugned expenditure item pertaining to prior period stood crystallized in the relevant previous year only. Both the learned representatives also invited our attention to the Assessing Officer‟s detailed discussion in his assessment order dated 28.12.2017 disallowing the assessee‟s claim.
We find no force in the Revenue‟s supportive arguments as there is no material in principle which has been rejected by the Assessing Officer while dealing with the assessee‟s crystallization plea. That being the case, we allow the assessee‟s impugned claim in principle and direct the Assessing Officer to examine its supportive evidence of crystallization of the corresponding expenditure items in the relevant previous year by quoting CIT Vs. Indian Petrochemicals Corporation Ltd. 2016 (9) TMI 110 – Gujarat High Court and case law CIT vs. Adani Enterprises Ltd. Tax Appeal 566/2016 (Guj) also holds that such prior period expenditure items ought not to be disallowed where the taxpayer concerned is assessed at the same rate
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all along. The second substantive ground is accepted for statistical purposes in foregoing terms.
The assessee‟s third substantive grievance seeks to reverse both the lower authorities action disallowing its interest paid on TDS amounting to Rs.1,71,338/- on the ground that the same is „penal‟ in nature. The Revenue strongly supported the impugned disallowance placing reliance on the learned lower authorities‟ action. We find no merit in its arguments in light of Lachmandas Mathuradas vs. CIT (2002) 254 ITR 799 (SC), DCIT vs. Rungta Mines Ltd. 2018 (10) TMI 672 – ITAT Kolkata and M/s. M.L. Reality vs. ACIT 2021 (9) TMI 877 – ITAT Mumbai holding such interest payment on delayed remittances of tax items as an allowable revenue expenditure u/s 37 of the Act. The impugned disallowance accordingly stands deleted.
Next comes the assessee‟s fourth substantive grievance that both the learned lower authorities have erred in law and on facts disallowing its claim of expenditure regarding education, secondary and higher education cess totaling Rs.8,69,48,904/- which indeed forms an allowable item in light of Sesa Goa Ltd. vs. JCIT (2022) 117 Taxman.com 96 (Bom). Learned counsel fails to dispute that the legislature has amended section 40(ii) of the Act vide Finance Act 2022 w.e.f. 01.04.2005 that such education cess is not an allowable expenditure item. We take note thereof to hold that the
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impugned claim of preceding cess(es) items is not allowable in law. The same stands rejected.
The assessee‟s next substantive ground pleads that both the learned lower authorities have erred in law and on facts in invoking section 115JB MAT computation which is not applicable in its case being a public sector banking company. We note with the able assistance of both the parties that the very issue had arisen between them in assessment years 2013-14 and 2014-15 (supra), wherein the learned co-ordinate bench‟s order dated 13.03.2020 has restored the same back to the CIT(A) as under: “20. The Ld. Counsel for the assessee further submitted that vide bifurcation of sub section (2) of Section 115JB in Clause (b), the Banking Companies are not under the scope of the provisions of section 115JB (2)(b) of the Act. The case of the assessee is that it is not Banking Company. The Ld. Counsel for the assessee also submitted that this issue was not raised before the Assessing Authority. However, the Ld. Counsel submitted that this matter came up for adjudication before the Ld. CIT(Appeals) who rejected the arguments of the assessee merely following of provision of Explanation 3 of the said section. The Explanation 3 is actually a sunset clause ending on 31.03.2012 vide Finance Act, 2012. The Ld. CIT(Appeals) ignoring the submissions of the assessee applied the said Explanation to the case of the assessee without giving into the essential core fact whether the assessee is Banking Company or Corporation or otherwise. 20.1 Before us, the Ld. Counsel for the assessee also submitted that they are not Banking Company. He referred to the events of nationalization of Banks that took place in the year 1970 and relevant Acts i.e. Banking Companies (acquisition and transfer of undertakings) Act 1970. 21. It is the case of the Revenue on this proviso that the assessee falls under the Banking Company and therefore, proviso to section 115JB of the Act still applicable to the Banking Company like the assessee. 22. In rebuttal, the Ld. Counsel for the assessee submitted that the assessee is neither the Company leave alone Banking Company and it is a Corporation created by the Special law of Parliament and therefore, the provisions of section 115JB cannot be applicable to the present case of the assessee. In this regard, the Ld. Counsel for the assessee has placed reliance on the following decisions:
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(i) ACIT Vs. Indian Overseas Bank, ITA No.948 & 777/Chny/2018 dated 22.01.2020. (ii) DCIT Vs. Damodar Vally Corporation 2018 (8) TMI 1363-ITAT Kolkata. The Ld. Counsel further submitted that amended provision on Finance Act, 2012 does not apply to a non- Banking Company like the assessee. 23. Further, referring to the computation provided in the statute as applicable to the companies and others, the Ld. Counsel argued that said procedure provided in the statute does not apply to the Corporation like the present assessee. 24. On hearing both the parties and perusing the orders of the Assessing Officer and Ld. CIT(Appeals) and also the amended Clause(b) read with proviso to Section 211(2) of the Companies Act, 1956, we find there is a requirement of verification of facts whether the assessee is a Banking Company or Corporation or otherwise. The orders of the Assessing Officer or the Ld. CIT(Appeals) are silent on the aspect of the arguments of the assessee that it is not a Banking Company. To that extent, the order of the Ld. CIT(Appeals) is not a speaking order as per Section 250(6) of the Act. Therefore, we are of the opinion that the order of the Ld. CIT(Appeals) stands erroneous so far as the interpretation of Explanation 3 of the Section 115JB of the Act. Explanation commencing on or before 01.04.2012 should be properly interpreted by the Ld. CIT(Appeals) in the remand proceedings. In view of the above facts and circumstances, we remand the issue back to the file of the Ld. CIT(Appeals) who shall pass a speaking order after hearing the submissions of the assessee on the aspect of applicability of provision 115JB of the Act. The Ld. CIT(Appeals) is also directed to adjudicate the issue in line with the status of the assessee whether it is Banking Company or Corporation or otherwise, procedure of computation of income provided in section 115JB of the Act, facts of the case etc. after providing reasonable opportunity of hearing to the assessee. Thus, ground No.5 raised in appeal by the assessee is allowed for statistical purposes. 25. Ground No. 6 is an alternative ground to Ground No.5. Since we have remanded the issue raised in ground No.5, accordingly, the issue raised in ground No.6 is also remanded to the file of the Ld. CIT(Appeals) with similar direction as given in ground No.5. The Ld. CIT(Appeals) is also directed to pass a speaking order considering the arguments raised before him. Thus, ground No.6 raised in appeal by the assessee is allowed for statistical purposes.”
Both the parties are fair enough in not pinpointing any distinction on facts or law qua the instant issue of applicability of section 115JB in assessee‟s case. There is further hardly any dispute as we have restored the assessee‟s foregoing second substantive grievance of prior period expenditure back to the Assessing Officer. Faced with the situation, we set
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aside the instant MAT issue as well back to the Assessing Officer for his afresh adjudication in light of CIT(A)‟s findings in the preceding assessment year (s) 2013-14 and 2014-15, as the case may be, as per law. Ordered accordingly.
No other ground has been pressed before us in assessee‟s appeal in ITA No.472/PUN/2020. The same is partly accepted in above terms.
We now advert to the Revenue‟s cross appeal ITA No.596/PUN/2020 raising the sole substantive grievance that the CIT(A) has erred in law and on facts in allowing assessee‟s claim of loss on valuation of Held to Maturity (HTM) securities amounting to Rs.20,64,08,969/- as an allowable revenue item thereby reversing the assessment findings to this effect. Suffice to say, it transpires during the course of hearing that the very issue had arisen before the learned co-ordinate bench in the preceding twin assessment year(s) wherein Revenue‟s corresponding substantive ground(s) stood rejected as under: “5. We have heard both the sides and perused the relevant paragraphs of the order of the Tribunal in assessee‟s own case (supra.) wherein, the Tribunal on the issue has held as follows: “2. The Revenue has assailed the findings of Assessing Officer on the single issue of allowing loss on valuation of securities Held to Maturity (HTM). 2.1 The ld. AR submitted that this issue has been let to rest by the Hon’ble Bombay High Court in assessee’s own case in Income Tax Appeal No. 920 of 2015 decided on 27-02-2018. The ld. AR further submitted that the Tribunal in appeal by the assessee in ITA No. 1370/PUN/2014 for the
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assessment year 2010-11 decided on 11-03- 2019 has also considered this issue and has decided in favour of assessee. 2.2 Mrs. Kesang Y. Sherpa representing the Department fairly admitted that the issue relating to loss on valuation of HTM securities has been considered by the Tribunal in assessee’s own case in immediately preceding assessment years. 2.3 Both sides heard. Orders of the authorities below perused. The Revenue is in appeal against the findings of Commissioner of Income Tax (Appeals) on the issue of loss on valuation of HTM securities. We find that the Commissioner of Income Tax (Appeals) has decided this issue in favour of assessee by following the order of Tribunal in assessee’s own case for assessment year 2005-06 in ITA No. 1505/PN/2008 and in ITA Nos. 1135 to 1138/PN/2013 decided on 17-08-2014. The issue of allowability of loss on valuation of HTM securities is recurring in assessment years after assessment years. The Co-ordinate Bench in assessee’s own case for assessment year 2010-11 in ITA No. 1370/PUN/2014 (supra) has decided this issue in favour of the assessee by placing reliance on the order of Tribunal in ITA No. 1505/PN/2008 and now the same has been upheld by the Hon’ble Bombay High Court in Income Tax Appeal No. 920 of 2015. For the sake of completeness the relevant extract of the findings of Tribunal in ITA No. 1370/PUN/2014 (supra) on this issue are reproduced here-in-below : “5.3 Both sides heard on the issue of disallowance of claim of loss in respect of securities held under HTM category. Both sides are unanimous in stating that the present issue was subject matter of appeal before the Tribunal in ITA No. 1505/PN/2008 and in ITA Nos. 1135 to 1138/PN/2013 (supra). The Co-ordinate Bench adjudicated the issue by observing as under: “20. In the background of the aforesaid legal position, a premise which can be drawn is that for the purposes of valuation of the closing stock it is permissible for the assessee to value it at the cost or market value, whichever is lower. In-fact, the Hon‟ble Supreme Court in the case of Chainrup Sampatram vs. CIT, (1953) 24 ITR 481 (SC) held that the assessee is entitled to value the closing stock either at cost price or market value, whichever is lower. In the present case, Revenue does not dispute that the method of the valuation adopted by the assessee, namely, valuing the stock either at cost price or market value whichever is lower, is a generally accepted method of valuation. No doubt, there are no statutory rules for the valuation of closing stock but the ordinarily accepted method of commercial accounting support the valuation of closing stock based on the lower of the cost or market value. Therefore, the departure from the erstwhile method of valuation of closing stock by the assessee is quite appropriate, and in fact is line with a method approved by the Hon‟ble Supreme Court in the case of Chainrup
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Sampatram (supra). In-fact, the only basis for the Revenue to challenge the bona-fides of the change is that the change has been effected only for the purpose of assessment of taxable income and is not incorporated in the account books. The aforesaid plea of the Revenue, in our view, is quite misplaced because it is well understood that assessee is a banking company and is statutorily mandated to maintain its books of account in terms of the RBI guidelines. On the other hand, the assessment of taxable income has to be based on the principle of law and cannot be guided merely by the treatment meted out to a particular transaction in the account books. In-fact, this aspect of the controversy has also been answered by the Hon‟ble Karnataka High Court in the case of Corporation Bank Ltd. (supra) by relying on the judgement of the Hon‟ble Supreme Court in the case of Kedarnath Jute Mfg. Co. Ltd. vs. CIT, (1971) 82 ITR 363 (SC). Therefore, we do not find any merits in the above objection of the Revenue. Moreover, the plea of the learned CIT-DR that nature of HTM securities is distinct from AFS and HFT securities and thus HTM securities are not stock-in-trade, is quite wrong. It cannot be denied that the securities held by the bank are stock-in-trade. Another plea of the learned CIT- DR was to the effect that the investments in the HTM category are not tradeable and the assessee may not be selling the HTM Securities prior to their maturity. Therefore, as per the learned CIT-DR, such securities could not be considered as „stock-in-trade‟. The aforesaid plea of the Revenue has been assailed by the learned Counsel for the assesseebank. He has furnished a statement showing net profit on sale of HTM Securities as per the Balance Sheet for the various assessment years, viz. 2006- 07 to 2009-10. On this basis, it is sought to be contended that the HTM category securities are also viewed as „stock-in-trade‟ by the assessee-bank. In our opinion, the plea of the learned CIT-DR is quite untenable primarily because the very nature of banking activities allowed as per the Banking Regulation Act, 1949 are in the sphere of business / trade activities; and, accordingly the recognition of investments in HTM category as „stock-in-trade‟ is not dependent on the frequency of their sale / purchase carried out by the assessee-bank. 21. In view of the aforesaid discussion, we, therefore, conclude by holding that in the present case the method of valuation of the closing stock adopted by the assessee i.e. cost or market value, whichever is lower is fair and proper and the income-tax authorities have erred in not accepting the same. The orders of the authorities below on this aspect are hereby reversed. “
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5.4 The ld. AR has further drawn our attention that the decision of Tribunal has been upheld by the Hon‟ble Bombay High Court in Income Tax appeal No. 920 of 2015 (supra). The copy of the Hon‟ble High Court order dated 27-02-2018 was furnished before us. A perusal of same shows that one of the question of law before the Hon‟ble High Court for consideration was : “(i) Whether on the facts and in the circumstances of the case and in law, the Tribunal was justified in deleting the addition of Rs.359,24,58,508/- in allowing loss of valuation of Held to Maturity (HTM) securities, when HTM securities are capital in nature?” The aforesaid question was decided by the Hon‟ble High Court in favour of the assessee upholding the order of Tribunal. Thus, in view of the fact that the issue has now been settled by the Hon‟ble High Court in favour of the assessee, we find merit in ground No. 3 of the appeal by assessee. Consequently, ground No. 3 raised in the appeal is allowed.” Since, the issue raised in present appeal is identical to the one already adjudicated by the Tribunal and no contrary decision/material has been placed on record by the Revenue, the ground raised by the Revenue in its appeal on the issue of disallowance of loss on valuation of securities held under HTM category is dismissed. 2.4 In the result, the appeal of Revenue is dismissed.” In view of the above decision, it is evident that this issue of allowability of loss in value of HTM securities was decided in favour of the assessee and against the Revenue in assessee‟ own case (supra.) by the Co-ordinate Bench of the Tribunal, Pune. Considering the settled nature of the issue, we are of the opinion that pending of the appeal before the Hon‟ble Supreme Court is not a ground for not adjudicating the issue before us. Accordingly, we find that the order of the Ld. CIT(Appeals) is fair and reasonable and same does not call for any interference. Hence, grounds raised by the Revenue in both the appeals are dismissed.”
The Revenue is fair enough in not pinpointing any distinction on facts or law before us. We adopt judicial consistency to uphold the CIT(A)‟s findings allowing the impugned loss on sale of “Held to Maturity (HTM)” securities to the assessee. The Revenue‟s sole substantive grievance as well as main appeal in ITA No.596/PUN/2020 stand rejected accordingly.
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To sum up, the assessee‟s appeal ITA No.472/PUN/2020 is partly allowed and the Revenue‟s cross appeal ITA No.596/PUN/2020 is dismissed in foregoing terms. A copy of this common order be placed in the respective case files.
Order pronounced in the Open Court on 30th June, 2022.
Sd/- Sd/- (DIPAK P. RIPOTE) (S.S. GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER पुणे Pune; ददिधांक Dated : 30th June, 2022 GCVSR आदेश की प्रतिलिपि अग्रेपिि/Copy of the Order is forwarded to: अपीऱधर्थी / The Appellant; 1. प्रत्यर्थी / The Respondent; 2. 3. The CIT(A)-1, Pune 4. The Pr.CIT-1, Pune 5. विभागीय प्रविविवि, आयकर अपीलीय अविकरण, पुणे “A” / DR „A‟, ITAT, Pune 6. गार्ड फाईल / Guard file आदेशानुसार/ BY ORDER, // True Copy // Senior Private Secretary आयकर अपीलीय अविकरण ,पुणे / ITAT, Pune
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Date 1. Draft dictated on 27-06-2022 Sr.PS 2. Draft placed before author 28-06-2022 Sr.PS 3. Draft proposed & placed before the JM second member 4. Draft discussed/approved by Second JM Member. 5. Approved Draft comes to the Sr.PS/PS Sr.PS 6. Kept for pronouncement on Sr.PS 7. Date of uploading order Sr.PS 8. File sent to the Bench Clerk Sr.PS 9. Date on which file goes to the Head Clerk 10. Date on which file goes to the A.R. 11. Date of dispatch of Order.