M/S. T & T MOTORS LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

M/s. T& T Motors Ltd. v. Addl. CIT Range- 16, New Delhi /I.T.A. No.6499/Del/2014/A.Y.10-11 Page 1 of 14

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D” NEW DELHI BEFORE SHRIK. NARASIMHA CHARY, JUDICIAL MEMBER AND SHRI O. P. MEENA, ACCOUNTANT MEMBER I.T.A. No. 6499/Del/2014: Assessment Year: 2010-11 M/s. T & T Motors Ltd. , Vs. Addl. CIT Range- 16, 4A-2, B-1, Extension, Mohan Industrial New Delhi Estate, Mathura Road, New Delhi 110044. PAN: AAACT5980 F Appellant Respondent

Assessee by Shri V. K. Aggarwal, A.R. and Ms. Sweta Bansal, CA Revenue by Smt. Nain Soin Kapil, Sr. D.R. Date of hearing 04.02.2019 Date of pronouncement 07.02.2019

ORDER PER O. P. MEENA, AM 1. This appeal by the Assessee is directed against the order of learned Commissioner of Income tax (Appeals)-19,New Delhi (in short “the CIT (A)”) dated 22.10.2014pertaining to Assessment Year 2010-11, which in turn has arisen from the assessment order passed under section 143 (3) dtd. 23.12.20111 of Income Tax Act,1961 (in short ‘the Act’) by the Addl. CIT Range-16, New Delhi (in short “the AO”). 2. Ground no. 1 is general in nature and do not require any specific adjudication. 3. Ground no. 2 states that the ld. CIT (A) has erred on facts and in law in confirming the disallowance of Rs. 24,97,826 made on account of leasehold repairs and maintenance expenses capitalized by the AO. 4. Brief facts as culled out from the orders of lower authorities are that the assessee has debited a sum of Rs.2,86,15,199 as per point 11(a) of Audit report towards leaseholdimprovement, repairs and maintenance and renovation expenses. On verification of invoices, the AO has noticed that expenses incurred through 5 invoices amounting to Rs. 27,97,826 [ i.e. two invoice both dtd. 18.12.2009 for Rs.

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6,77,327 are for electrical lights and for Rs. 7,04,492 for Luminaire Frame from M/s. Artlite Illumination Pvt. Ltd.,invoice from Iqbal Khan dtd. 3.11.2009 for dismantling work etc., invoice dtd. 10.09.2009 from Arti Interiors for Rs. 2,72,048 and invoice dtd. 25.06.2009 of Rs. 5,24,056 from Taj Hi Tech are for Epoxy Flooring (coating) are capital in nature] as these gives enduring benefit to the assessee. Hence, the assessee was asked to explain as to why these should not be capitalized. It was explained that the expenses were incurred for dismantling and colour work and to make the showroom and workshop more attractive. The assessee being tenant of premises does not become owner of modification carried out. Hence, these expenses are revenue in nature being current repairs and therefore, allowable as business expense. However, the AO was of the view that these expenses are capital in nature. Accordingly, the AO has capitalized these expenses and after allowing depreciation @10% made the disallowance of balance expenses of Rs. 24,97,826. 5. Being aggrieved, the assessee filed an appeal before the ld. CIT (A). However, the ld. CIT (A) after going through the invoices observed that expenses have been incurred towards suspended lights, outdoor flooring recessed luminaire framemade of brushed metal and installation of epoxy flooring, hence, capital in nature. Ld. CIT (A) also observed that the assessee has failed to demonstrate that the facts of the case are same as held by Tribunal in its order for assessment year 2001-02. In view of this, the disallowance so made were confirmed. 6. Being, aggrieved the assessee filed this appeal before the Tribunal. The learned counsel for the assessee submitted that the business of the assessee is being dealer of motor vehicles in particular high end Model Cars of Mercedes Benz has to exhibit the said vehicle for attracting customers thereby improving the business of the assessee. Apart from this, the assessee also under takes servicing of vehicles. The Principal, Mercedes Benz India Pvt. Ltd. has specific norms and requirement with regard to appearance of showrooms/workshops worldwideand dealersto follow the norms and keeps changing year to year. The invoice placed at Paper Book Page No. 95 to 99 shows that expenditure incurred is to make workshops and showrooms attractive. The first two invoices are for fancy lamps along with their accessories, which were installed in the Gurgaon showrooms,and other three invoices give details

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regarding civil work done forflooring etc. at the workshops in Okhla Industrial Area. The expenditure did not result bringing into existence of neither any new asset nor the expenses has enduring benefit to the business. The assessee being a tenant does not become owner of the modification carried out in the rented out premises as the are either held or fastened to the ground and these could not be removed and carried in the present state after modification. The expenditure has been incurred with the object to improve sales and creating image of the assessee company. Thus, expenditure is revenue in nature. The learned Counsel further, submitted that similar expenses were allowed by the ITAT in assessee`s own case in assessment year 2001-02 vide order dated 23.03.2007 in I.T.A.No. 430/Del/2005 (copy filed PB-55, Para 9). Further, the CIT (A) has allowed similar expenses in A.Y. 2007-08 vide order dated 15.04.2010 in appeal No. 132/2009-10 (PB-69-70) and the Department has accepted the same. The learned counsel for the assessee also supported his view by placing reliance in the case of CIT v. Madras Auto Service (P) Ltd. [1998] 233 ITR 468 (SC) wherein the assessee acting under lease agreement demolished the old premises and constructed new premises which was belonging to lesser and not to lessee, the expenditure was held to be revenue in nature. The learned counsel for the assessee further submitted expenditure incurred on networking,firefighting cabling, tiling, sanitary and partition was held to be revenue in nature by the ITAT Delhi in ITO v. ACL Wireless Ltd. 2012-TIOL-768-ITAT-DEL and HCL Comnet Ltd. v. DCIT 2012-TIOL- 649-ITAT-DEL 7. Per contra, the ld. Sr. D.R. vehemently contend that expenditure incurred for epoxy tiles gives enduring benefit. She also took us through invoices placed in Paper Book and argued that the expense incurred for installation of lighting, flooring are in the capital in nature. Further, it is not known whether premises has been taken on lease may be more than 99 years of lease hence, expenditure so incurred is capital in nature. Hence, CIT (A) has rightly upheld the disallowance made by the AO. 8. Replaying to above, the learned counsel for the assessee filed copies of Lease agreement in respect of Gurgaon and Okhla Industrial Area premises indicating that lease was for three years and one year’srespectively on renewal basis,hence, it is asserted that the expenditure s is not the property of the assessee and o incurred on

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rented premises does not bring any new asset to the assessee as the same cannot be removed. 9. We have heard the rival submissions and perused the relevant material on record.We find that the assessee is a dealer in high-end vehicles of Mercedes Benz, whichhas to exhibit the said vehicle for attracting customers thereby improving the business of the assessee. Apart from this, the assessee also under takes servicing of vehicles.Further, the Principal, Mercedes Benz India Pvt. Ltd. has also specific norms and requirement with regard to appearance of showrooms/workshops worldwide and dealers to follow the norms and keeps changing year to year. The perusal of invoices placed at Paper Book Page No.95 to 99 demonstrate that these are for fancy lamps along with their accessories which were installed in the Gurgaon showrooms and other three invoices gives details regarding civil work done for flooring etc. at the workshops in Okhla Industrial Area. Therefore, we are of the view that the expenditure has been incurred on rented premises leased for two /three years as could be seen from lease agreement with the object to improve sales and creating image of the assessee company which does not result bringing into existence of neither any new asset nor the expenses has enduring benefit to the business. The assessee does not become owner of the modification carried out in the rented out premises as the are either held or fastened to the ground and these could not be removed and carried in the present state after modification.Thus, the expenditure are revenue in nature. It has been pointed out that similar expenses were allowed by the ITAT in assessee`s own case in assessment year 2001-02 vide order dated 23.03.2007 in I.T.A.No. 430/Del/2005 (PB-55). Further, the CIT (A) has allowed similar expenses in A.Y. 2007-08 vide order dated 15.04.2010 in appeal No. 132/2009-10 (PB- 69-70) and the Department has accepted the same. The learned counsel for the assessee also supported his view by placing reliance in the case of CIT v. Madras Auto service (P) Ltd. [1998] 233 ITR 468 (SC) wherein the assessee acting under lease agreement demolished the old premises and constructed new premises was belonged to lesser and not to lessee, the expenditure was held to be revenue in nature. We find that expenditure incurred on networking,firefightingcabling,tiling, sanitary and partition was held to be revenue in nature by the Co-ordinate Bench of ITAT, Delhi in

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ITO v. ACL Wireless Ltd. 2012-TIOL-768-ITAT-DEL. In HCL Comnet Ltd. v. DCIT 2012- TIOL-649-ITAT-DEL, it was held that the expenses were incurred for dismantling and colour work and to make the showroom and workshop more attractive. On careful consideration of above facts and case laws, we are of the opinion that expenditure incurred by the assessee on suspended lights, outdoor flooring recessed luminaire frame made of brushed metal and installation of epoxy flooring, tiles is for making the rented premises more attractive and presentable with commensurate as dealer of high end vehicles as tenant of premisesbeing in the nature of current repairs and therefore, revenue in nature and allowable as business expenses. Hence, the lower authorities were not justified in treating the same as capital in nature and consequently, capitalizing it. In view of this matter, the disallowance of Rs. 24, 97,826 is thereforedeleted. Ex-consequenti, this ground of appeal of the assessee is allowed. 10. Ground no. 3 states that the ld. CIT (A) has erred on facts and as well as in law in confirming the disallowance of Rs.1,00,443 made on account of interest paid to M/s. Talbros Automotive Components Ltd. (herein after referred as TACL) on Inter Corporate Deposit (ICD)by reducing the rate of interest from 12% to 11%. 11. Facts apropos of this ground are that the assessee has paid interest @ 12% on loan taken from related concern i.e. M/s. TACL,whereas it has paid interest @ 11% to other three related concerns. It was noticed that the loan was taken in earlier year on which interest @10% was being paid. During the year under consideration, the assessee has increased interest rate to 12% due to market conditions. The AO observed that the assessee has not justified the burden of proof to establish reasonableness of expenses payment made to person specified under section 40A(2)(b). Therefore, the AO noted that interest paid is found to be excessive hence, hence, the AO has restricted the interest payment to 11% which has resulted in disallowance of interest of Rs.1,00,443 and consequent addition to income. 12. Being aggrieved, the assessee filed an appeal before the ld. CIT (A). The CIT (A) observed that the assessee has failed to establish as to how it has paid interest @ 12% to related party even though he has himself taken loan @10% of interest and paid interest @ 11% to related concerns. Even otherwise disallowance can be made under

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section 36(1) (iii) because the excess interest paid not for the purpose of business and profession, but for the personal benefit. It was for the appellant to furnish complete details of shareholding in support of his claim that section 40A(2)(b) is not applicable. The CIT (A) observed that the assessee has given a vague reply that interest rate was increased during to market condition but did not substantiate the same. Accordingly, the disallowance so made by the AO were confirmed. 13. Being, aggrieved the assessee filed this appeal before the Tribunal. The learned counsel for the assessee submitted that neither M/s. TACL nor its directors/members have any substantial interest in the assessee company because all the shareholders are having less than 20% of shareholding(PB-80-90) with the assessee company, hence, provisions of section 40A(2)(b) are not attracted. Further,without prejudice, the assessee has taken ICD in F.Y. 2006-07 and details of which were filed vide letter dated 18.03.2013. Subsequently on representationfrom the party, the interest rate was revised to 12% to maintain liquidity.The assessee has already given ICD to two companies @11% (PB90-93). Therefore, the AO has disallowed the interest on the ground that payment made is excessive under section 40A(2)(b) of the Act. He completely ignored the facts that rate of interest of 11% from three companies are continuing from earlier year`s when the assessee was paying interest @10% Therefore, increase of interest rate @12% due to market conditions is justified. Hence, interest paid @12% was reasonable and not excessive. 14. Au contraire, the ld. Sr. D.R. supported the orders of lower authorities and contended that the assessee company has failed to substantiate with evidence its claim that interest rate was increased due to market conditions. 15. We have heard the rival submissions and perused the relevant material on record. We find that the assessee has taken ICD in assessment year 2006-07 from M/s. TACL and has been paying interest @10% since then. It is true that provisions of section 40A (2)(b) are not attracted as shareholding of lender company/ directors/ members is less than 20% . However, it is also fact that M/s. TACL is related person within the meaning of section 40A(2)(b) of the Act. We find that the ld. CIT (A) has upheld the disallowance on the ground that the assessee has made vague reference of market conditions but has failed to adduce any documentary evidence and

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substantiate the claim of increase in interest rate to 12%. The ld. CIT (A) has also observed that the assessee has not filed complete details of shareholding before the AO in support of its claim that provisions of section 40A(2)(b) are not attracted. We further notice that the assessee has been paying interest @10% to other related concerns/persons i.e. M/s. Gyan Enterprise Pvt. Ltd. as reflected in the table given at Page No. 9 of assessment order and interest @11% to M/s. AAB Enterprise and M/s. Beacon Sales Pvt. Ltd. as reflected at Page No. 10 of assessment order. In such circumstances, we are of the considered opinion that the increase in interest rate from 10% to 12% without bringing and substantiated and bringing any evidence on record is not justified, notwithstanding the fact that the assessee has taken ICD loan on interest rate of 10% from M/s. TACL. Further no evidence has been adduced to substantiate the excessiveness of interest rate @12% asper provisions of section 36(1) (iii) of the Act as interest paid is for personal benefit and not for business purpose, when the assessee has been paying interest @11% for other persons. Therefore, the AO was quite justified in restricting the increase in interest rate to 11% with commensurate with other parties. In view of this matter, we find do not find any infirmity in the order of CIT (A), accordingly, same is upheld. This ground of appeal is therefore, dismissed.

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under consideration. Reliance was also placed on the decision in the case of CIT v. Exxon Mobile Lubricants Pvt. Ltd. [2010] 328 ITR 17 (Delhi) wherein it was held that where the liability for payment was determined and crystallized in the year under question and therefore, allowable and it cannot be held to be prior period merely because the expenses related to a transaction of earlier years. However, the CIT (A) upheld that disallowance by holding that the assessee has not followed the standard of accounting principle by not making provisions of prior period expenses. 19. Being, aggrieved the assessee filed this appeal before the Tribunal. The learned counsel for the assessee took us through the demand letter dtd. 30.07.2009 placed at Paper Book Page No. 130 which clearly explained that M/s. Okhla Industrial Area Society has raised a demand note for the first time for this demand on account of contribution towards assessee`s share for operating and maintenance cost of CETP. The demand letter clearly states that demand was not notified earlier as there was no such reference in their letter. The charges are keep changing every year as indicated in the said letter. Therefore, the liability was crystallized and determined during the year under consideration, hence, the expenses incurred and paid during the year under consideration is allowable as business expenses for year under consideration. 20. On the other hand, the ld. Sr. D.R. relied on the orders of lower authorities. 21. We have heard the rival submissions and perused the relevant material on record. On careful consideration of facts and perusal of demand letter dtd. 30.07.2009, (PB-130) it is discernible that M/s. Okhla Industrial Area CETP Society has determined the amount of assessee`s contribution after reducing the charges for operation and maintenance cost of CETP during the year under consideration. Though the liability pertained to arrears including the period up to 31.03.2009, but it has been crystallized and determined vide letter dated 30.07.2009.Thus, the liability has been determined and crystallized during the year under consideration and also paid during the year under consideration, hence, same is being business expenditure is allowable as expenses. Since the liability was not ascertainable and quantified hence, provision could not be made in earlier years.Our view is also supported from the judgement of Hon`ble Jurisdictional High Court of Delhi in the case of CIT v. Exxon Mobile Lubricants Pvt. Ltd. (supra) wherein it was held that where the liability for

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payment was determined and crystallized in the year under question and therefore, allowable and it cannot be held to be prior period merely because the expenses related to a transaction of earlier years.In view of these facts and circumstances and following the decision of Hon`ble High Court, we hold that the liability of prior period expenses has been determined and crystallized vide letter dated 30.07.2009, hence, these expenses on account of rate and taxes are allowable as business expenses. In view of this matter, the disallowance of Rs.2,45,794 sustained by the Ld. CIT (A) are therefore, deleted. This ground of appeal is allowed.

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aside to the file of the AO to exclude the share application money. The AO has worked out disallowance u/s. 14A by excluding the share application money as not a part of investment in shares for the purpose of Rule 8D (PB-153) The revenue has accepted this decision as no appeal has been filed; hence, disallowance made on this account may please be deleted. It was further submitted that the AO has not established any link between expenditure and exempt income. The learned counsel for the assessee has also contended by relying on the decision in the case of A C B India Ltd. v. ACIT TIOL-176-HC-2015-DEL that only those investment has to be considered which yielded tax exempt income. The learned counsel for the assessee further placed reliance in the case of ACIT vs. Vireet Investment (P.) Ltd (2017) 82 taxmann.com 415 (Delhi-Trib.)(SB). At last the learned counsel for the assessee submitted that at most worst scenario the average value of investment under Rule 8D(2)(iii) would be Rs. 17,03,220 i.e. [ 1,05,264+ 1,05,264+ 31,95,911/2]. Therefore, 0.05% of the average value of investment would be Rs. 8,516 , hence, disallowance u/s. 14A should be restricted to Rs. 8,516. It was also contended by relying in the case of Joint Investment Pvt. Ltd. v. CIT [2015] 59 taxmann.com 295 (Delhi) that disallowance u/s. 14A cannot be swallowed the whole exempt income. 26. We have heard the rival submissions and have gone through the orders of the lower authorities, and perused the material available on record. It is noticed that the assessee has earned dividend income of Rs.73,639. However, the expenditure incurred in relation to earning such exempt income is not quantified during the course of assessment proceedings. We find that the claim of the assessee that no expenditure has been claimed has not been examined by the AO as he had made disallowance merely by applying Rule 8D of Income Tax Rules, 1962. We find that the assessee had its sufficient own funds in the form of share capital and reserves of Rs. 20.84 crores as against investment inexempt income yielding investment. Further, the assessee has earned profit at Rs. 5.04 crores in preceding assessment year, which is enough to cover the investment. Therefore, the presumption would be that the investment in exempt income yielding investment is made out of interest-free funds as held by the Hon`ble Bombay High Court in the case of CIT vs. Reliance Utilities & Power Ltd. (2009)313 ITR 340 (Bom)/ 178 Taxman 135 (Bom) wherein it has been laid

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down that where the assessee had both interest bearing borrowed funds and interest- free own funds and if own funds were sufficient to meet investment yielding tax free income, then it can be presumed that such investments were from interest-free funds and not from borrowed funds. Therefore, we are of the considered opinion that no disallowance on account of interest is called for under Rule 8D (ii) of Income-Tax Rules, 1962. We further find that the auditors in tax audit report has pointed out disallowance u/s. 14A as NIl. We further observe that the Tribunal in assessee`s own case in assessment year 2009-10, in I.T.A.No. 6490/Del/2012 dtd. 07.01.2015 has held that share capital and reserve and surplus has held that these are far exceeded the amount invested in securities; therefore, disallowance of interest was deleted. Therefore, following the said reasoning and order of tribunal , the disallowance of interest of Rs.20,12, 865 in respect of interest under Rule 8D(2)(ii) are not to be considered as same are directly related to business income. Therefore, disallowance of interest of Rs. 20,12,865 is therefore, deleted. We also observe that tribunal in assessment year 2008-09 has directed the AO to exclude the share application money vide order dated dtd. 20.11.2013 in I.T.A.No. 5096/Del/2011 and the AO has accordingly, excluded the same therefore, no disallowance under Rule 8D(2)(ii) is required. It is seen that that the AO has not established any link between expenditure and exempt income whereas onus lies on him as held by tribunal in the case of ACIT v. S I L Investment Ltd. 2012-TIOL-334-ITAT-DEL-as relied by the learned counsel for the assessee. The investment in dividend yielding investment made in with TACL in which investment is made in earlier year out of interest-free funds or own funds and second investment has been made in SBI mutual fund were also made in earlier year`s. We may observe that section 14A of the Act postulates and states that no deduction shall be allowed in respect of expenditure incurred by an assessee in relation to income, which does not form part of the total income under the Act. Under sub Section (2) to Section 14A of the Act, the Assessing Officer is required to examine the accounts of the assessee and only when he is not satisfied with the correctness of the claim of the assessee in respect of expenditure in relation to exempt income, he can determine the amount of expenditure which should be disallowed in accordance with such method as prescribed, i.e. Rule 8D of the Rules (quoted and elucidated below).

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Therefore, the AO at the first instance must examine the disallowance made by the assessee or the claim of the assessee that no expenditure was incurred to earn the exempt income. If and only if the AO is not satisfied on this count after making reference to the accounts, that he is entitled to adopt the method as prescribed i.e. Rule 8D of the Rules. Thus, Rule 8D is not attracted and applicable to assessee who have exempt income and it is not compulsory and necessary that an assessee must voluntarily compute disallowance as per Rule 8D of the Rules. Where the disallowance or ‘nil’ disallowance made by the assessee is found to be unsatisfactory on examination of accounts, the assessing officer is entitled and authorised to compute the deduction under Rule 8D of the Rules. 27. The learned counsel for the assessee submitted that at most the disallowance can be restricted to Rs.8,516 being 0.05% of value of investment of Rs. 17,03,220 [ 1,05,264+ 1,05,264+ 31,95,911/2]. However, this working has not been verified by the AO. Therefore, disallowance u/s. 14A are restricted to Rs.8,516 and balance disallowance is deleted subject to verification by the AO that the assessee has correctly taken the average value of investment after excluding of share capital and reserve& surplus, and only considering exempt income yielding investment and excluding interest of Rs.20,12,865, which is directly attributable to business income. Subject to terms as indicated above, this grounds of appeal is partly allowed. 28. In the result, the appeal of the assessee is partly allowed. 29. The order pronounced in the open Court on 07.02.2019

Sd/- Sd/- (K.NARSIMHA CHARAY) (O.P.MEENA) JUDICIAL MEMBER ACCOUNTANT MEMBER New Delhi:Dated:07 February 2019/opm Copy of order sent to- Assessee/AO/Pr. CIT/ CIT (A)/ ITAT (DR)/Guard file of ITAT. By order

Assistant Registrar, New Delhi

Standard preparation & delivery of orders in the ITAT 1 Date of dictation 04.02.2019 2 Draft placed before the Author 07.02.2019

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3 Draft proposed & placed before Second Member 07.02.2019 4 Draft discussed/ approved by Second Member 07.02.2019 5 Approved Draft comes to Sr. PS /PS 07.02.2019 6 Kept for pronouncement on 07.02.2019 7 Date of uploading order on the web site 07.02.2019 8 File sent to Bench Clerk 9 Date on which the file goes to the A.R. for signature on the order 10 Date on which file goes to Head Clerk 11 Date of dispatch of order