DCIT (TDS), DEHRADUN vs. THE JOINT SECRETARY, DEHRADUN

PER PRASHANT MAHARISHI, A. M. 1. These are the five appeals pertaining to the same assessee. In

four appeals for two assessment years preferred by assessee

and revenue are concerning short deduction of tax u/s 201(1)

and Interest u/s 201 (1A) of the Income Tax Act involving

similar issues and one appeal preferred by assessee against

confirmation of penalty u/s 271C of the act for AY 2010-11 .

These appeals are argued issue wise by both the parties together

and, hence, these are disposed of by this common order.

the order of the ld Commissioner of Income Tax ( CIT(A)) dated

03.11.2012 for Assessment Year 2009-10 and 2010-11

respectively , wherein, he has held that the assessee is required

to deduct tax at source u/s 194C of the Act on payment made to

different parties. The assessee contested before him that the 626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

3 order passed by the ld Assistant Commissioner of Income tax

(TDS) (ACIT(TDS)) , Dehradun passed u/s 201(1) read with

section 201(1A) of the Act on 30.03.2011 is not sustainable. The

ld AO has also filed appeals for two assessment years contesting

the finding of the ld CIT (A) that the assessee is not required to

deduct tax at source of payment made to foreign companies’ u/s

195 but u/s 194C of the Act. The ld AO further aggrieved against

the finding of the ld CIT (A) that the assessee is not required to

deduct tax at source on payment to the State Trading

Corporation of India Ltd u/s 194C as the contract was for supply

of the equipment and not for work.

organizing SAF winter games, 2009( games) in Uttrakhand and

is involved in development of infrastructure facilities such as

stadiums, ice skating rink, development of Ice skiing slopes,

ancillary sports facilities and other infrastructure for games.

Survey u/s 133A of the Act was conducted on 31.01.2011 and it

was noticed that assessee is required to deduct tax at sources on

payment made to various parties, which has not been deducted.

Summons u/s 131 of the Act was also issued to the Accounts

Officer of the assessee. The ld AO noted that the assessee has

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4 made a payment to foreign party in France/ Italy on which no tax

is deducted u/s 195 of the act. The assessee has contested that

payment was made for the purchase of equipments and

therefore, no tax is required to be deducted. The ld AO rejected

the contention of the assessee and on reading of the contract

held that the payment is covered u/s 9(1)(vii) of the Act as fees

for technical services. Hence, provision of section 195 of the Act

applies and the assessee should have deducted tax at source of

Rs. 297045/- @10.5575%. He further charged interest u/s

201(1A) of the Act.

to other parties and it was noted by him these parties are

engaged in construction work for games and TDS u/s 194C of

the Act should have been made on payments to them. Assessee

explained that these are government departments and payments

are made to these agencies in the form of grants based on

utilization of funds. Hence, it was contended that no tax was

required to deduct. The ld AO rejected the contention of the

assessee holding that payments are made by the assessee for

construction work of various infrastructure facilities. He further

held that grants are not shown that it has been transferred

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

5 without any control etc. He further held that the payments made

to various concerns are subject to TDS u/s 194C of the Act. He

therefore, held that TDS @2% should have been deducted and

worked out short deduction of Rs. 2806886/- and interest

thereon of Rs. 1018645/-.

8.69 crores to State Trading Corporation India Ltd., for which

assessee submitted that payment are for import of equipments

along with installation and commissioning charges and no tax is

required to be deducted thereon. AO also rejected this argument

holding that assessee has imported material/ equipment from

other through STC and it has acted as agent of the assessee and

incurred various incidental expenses such as duty, clearance

charges, freight and other expenses , which are covered u/s 194

C of the act.

passed on 30.03.2011 for AY 2009-10. Identical are the facts for

AY 2010-11.

the years and the ld CIT (A) also passed orders in both the cases

on the same date.

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6 8. The ld CIT (A) with respect to the payment to foreign parties, he

considered the submission of the assessee that along with the

foreign companies and the Indian company a consortium was

formed where the clear responsibilities were laid down. The

foreign company was to supply the equipment for which separate

invoices were raised therefore, according to the assessee it is

payment for sale of goods, hence, contract for sale and not

contract for work. The assessee further stated that consortium is

an association of person and foreign party has merely sold goods

to the assessee tax was not required to be deducted on that. In

view of this, the ld CIT (A) held that as the payment is made to a

consortium and the whole payment was to be made for the

purpose of the work, tax is required to be deducted at source on

the payment made but same is not covered by the provision of

section 195 of the Act, but covered u/s 194C of the Act. He

accordingly directed the ld AO to compute the shortfall. The

revenue is aggrieved with this finding and has preferred appeal

before us. The assessee, is also aggrieved with direction of the ld

CIT (A) to compute TDS applying the provisions of section 194C

of the Act hence, it is in appeal.

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

7 9. With respect to payment made to other public sector

undertakings, assessee submitted that payments have been

made in connection with various works relating to construction

of the infrastructure works for the winter games and funds were

provided to these entities as grant without calling for any tenders

or certificate for utilization. It was further stated that these

recipients got the work done by engaging the services of various

contractors and deducted tax at source on the payment made by

them to those contractors. It was further submitted that there

was no contract entered into with these entities by the assessee

and no bills have been raised by those parties on the assessee

and it is merely a disbursement of grant, which does not

constitute consideration for any work-defined u/s 194C of the

Act. Ld CIT (A) rejected this contention of the assessee and held

that assessee is required to deduct tax on the payment made to

these entities as the payment is for the consideration for work

actually done by these parties. He further held that the

contractor engages the services of sub-contractor for getting work

done and deduct tax on the payment made to sub-contractor,

cannot absolve the original payee from tax deduction on payment

made to contractor. He therefore, upheld the applicability of

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

8 provisions of section 194C of the Act. Assessee aggrieved has

filed appeal before us.

Trading Corporation of India for supply of material. As the

invoices raised by STC showed that the payment has been made

for import of equipment along with incidental jobs including

custom clearance, handling charges etc, AO held that on the

whole payment tax is required to be deducted u/s 194C of the

Act. Assessee submitted before the ld CIT (A) that STC has

undertaken to import and supply the equipment as per the

requirement of the assessee and the assessee has purchased the

material on which no tax is required to be deducted, as it is a

contract for sale of goods. The ld CIT (A) held that as the

Assessing Officer himself held that tax was required to be

deducted with reference to only incidental expenses but

computed the TDS on the supply of material also. In view of this,

he held that no tax is required to be deducted on this sum. The

revenue aggrieved with this finding, has preferred appeal before

us.

when the payments have been made to a foreign party for

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

9 purchase of the goods, no tax is required to be deducted. He

further referred to the decision of Hon'ble Supreme Court in DIT

Vs. Linde AG Linde Engineering Division 73 Taxmann.com 212

(SC) and submitted that per circular No. 7 of 2016 dated

07.03.2016, no tax is required to be deducted as the consortium

fulfills the conditions as laid down in para 3 of that circular. In

view of this, he submitted that the ld CIT (A) has wrongly held

that tax is required to be deducted u/s 194C of the Act. In short

his argument was that tax is not at all required to be deducted

either u/s 195 or u/s 194C of the Act. He further relied on

several decisions. He further stated that property in the

equipment has passed outside India, which is evident from the

fact that customs duty was paid by the assessee itself and

assessee became owner of the goods prior to its shipment in

India. Hence, no income arises to the recipient in India.

assessee is merely a pass through entity that has been granted

sum for organizing the South Asian Winter Games and it did not

enter into any contract with the parties to whom payments have

been made. He further stated that all the recipient of the sum

has in turn given contracts to the various sub contractors and

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10 they have already deducted tax at source on payments made by

them to such sub contractors. He further vehemently relied on

paper book page No. 34 which is a copy of letter dated

14.03.2011 and stated that payments were made as grant to

these parties and those parties have sent their utilization

certificate for the amount utilized during the financial year.

These executing agencies raise no bills; no payments were also

made according to works completed but it is advances. He

further stated that only lump sum grant was issued for getting

the work done and utilization received. He therefore, stated that

liability of TDS does not arise in these cases.

included the above amount in their income and already paid

taxes on these incomes. He therefore, stated that if in such a

situation, if tax is recovered from the assessee, it would be an

exercise in futility as on the one hand the assessee is required to

pay the tax and on the other hand, the payee would be required

to claim the refund. He vehemently relied upon the decision of

the Hon'ble Supreme Court in Hindustan Coca Cola Beverages

pvt. Ltd Vs. CIT 293 ITR 226 for this proposition. He further

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

11 relied upon his submissions made at page No. 1 to 15 of the

paper book also.

the order of the ld AO and submitted that with respect to the

payment to the foreign party stated to be made towards purchase

of goods is in fact payment made to an Indian party which is an

AOP for the complete work and not only for sale of goods, then

payments made such consortium should have been subjected to

TDS. AOP circular is for AO of AOP to decide how it is to be

taxed; it has no relevance as far as the liability of assessee for

TDS is concerned. With respect to the other payment, he

submitted that assessee is the party who got the work executed

and made the payment. Therefore, provisions of section 194C of

the Act are clearly applicable to the facts of the case. He

submitted that even if the recipients has deducted tax on the

works contract executed by sub-contractors cannot absolve the

assessee from its duty to deduct tax at source on payment made

to them. He further stated that in case of STC the tax should

have been deducted by the assessee on total sum including the

payment for purchase of goods as STC has incurred several

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

12 expenditure on behalf of assessee, which amounts to carrying on

of the work as per provisions of section 194C of the Act.

the orders of the lower authorities. The brief facts of the case are

that assessee is a body registered under The Societies

Registration Act set up for organizing the South Asian Winter

Games 2009. It is implementing agency for the games. The ld AO

has conducted survey u/s 133A of the Act and found that on

several payments assessee has failed to deduct tax at source and

therefore, the orders u/s 201(1) and 201(1A) of the Act were

passed. Ld CIT (A) granted part relief. Various issues arising in

the appeal are dealt with hereinafter.

consortium AOP who won the bid, the ld AO held that tax is

required to be deducted u/s 195 of the Act and the ld CIT (A)

held that these are the payment made to an AOP and therefore,

tax is required to be deducted u/s 194C of the Act. The assessee

has entered into a consortium agreement with two foreign

companies and one Indian company for rendering services with

respect to construction of water storage and installation of ski lift

and comprehensive maintenance for three years. The assessee

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

13 has stated that the consortium has demarcated duties with

respect to each of the parties. The foreign parties were only to

supply various equipments and Indian party was to install those

equipments. The assessee submitted the agreement of the

consortium, which is placed at page No. 48 of the Paper book.

According to the agreement, scope of the services by the various

parties is described in Appendix A. On reading of the scope of

services, it is apparent that Snow star SPA was to supply various

equipments and the scope of services of Pomagamsky SA was to

supply various equipments and warranty for equipments. The

Indian party Spaceage Power Ltd was to install and perform the

civil work. The payment was also specified separately as per

clause 7 of the agreement. Each of the party was also responsible

for the work carried out by them. The services are also specified

in clause 1 of the agreement. The responsibility is also mentioned

at page No 78 to 80 of their agreement. In such a contract, it was

an issue whether the consortium constitutes and association of

person i.e. a separate entity for charging of the tax or whether

each of the members is liable on their individual share of the

contract. This aspect has been clarified by the CBDT by issuing

Circular No. 7/ 2016 dated 07.03.2016 wherein, para NO. 3 it

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14 has laid down certain conditions and on fulfilling such conditions

the consortium will not be treated as an AOP. In the present case

all the members are independently responsible for executing their

work. The foreign parties are required to supply the equipments

only along with the warranty. Further, the payments have been

made directly to those parties and naturally, each of them

individually charged to tax on their profits or losses. It is

apparent that the common management is only for

administrative convenience. Assessee has also made payment

directly to the foreign equipment suppliers. It is not shown to us

that any of the conditions stated in that circular are not fulfilled.

In view of this, we hold that assessee has made payment to the

foreign parties independently, directly and it shall be chargeable

to tax in their own hands. Now the issue arises is that whether

payment made to them is subject to deduction of tax u/s 195 in

the hands of those parties or not. The assessee has shown bills

raised by those parties placed at page No. 99 to 100 of paper

book. The custom duty has also been paid by the assessee. The

bills have also been raised by those parties on the assessee itself.

The payments are also made as advances through letter off

credits. On looking at the various bills, it is found that goods

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15 have been shipped by those parties from outside India. It is not

shown by the revenue that title of the goods has passed in

India. Contrary to that, it is consistently claimed by the assessee

that title in the goods has passed outside India. Further though

ld AO has held that tax is required to be deducted t sources on

such payments but it is not shown that how the income of

foreign parties who supplied equipments are chargeable to tax in

India. In view of this, it is apparent that title in the goods have

passed from the suppliers to the assessee outside India at the

port of shipment. In view of this, it is not controverted that no

income has accrued to those parties in India in terms of

provisions of section 5 and section 9 of the Act, therefore,

provisions of section 195 does not apply to these payments. In

view of this, we hold that assessee was not required to deduct

Tax at source either u/s 194C or section 195 of the Act on

payments made to Snowstar SPA Italy and Pomagalsky SA. In

view of this ground No. 1 to 3 of the appeal of the assessee are

allowed.

various parties which are public sector undertaking such as

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

i. Uttranchal Jal Sansthan, ii. Uttranchal Power Corporation Ltd,

iii. Uttar Pradesh Nirman Nigam Ltd,

iv. Winter Gems Federation of India, v. Gharwal Mandal Vikash Nigam Ltd.

The assessee has made these payments as an advance to the

parties for carrying out various works with respect to the Winter

games 2009. These payments are required to be tested u/s 194C

of the Act and whether tax is required to be deducted at source

on such payments. According to the provisions of section 194C of

the Act, tax is required to be deducted under following

circumstances:-

i. Tax is required to be deducted by the person who is

responsible for payment to any resident.

ii. Such payment has to be for the sum for carrying out any

work as defined under explanation (iv) of the Act.

iii. The payment has to be in pursuance with the contract

between the contractor and specified person. Specified

person has been defined under explanation (i) of the

section.

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

17 iv. The tax is required to be deducted at the earliest point of

time of credit to the account of contractor or the payment.

v. The provisions specify the prescribed percentage of tax

deduction.

vi. It is deduction of tax on gross sums paid unless otherwise

specified u/s 194C (3) of the act.

specified person covered under explanation (i)(g) being a society

registered under the Societies Registration Act 1860. Therefore,

the liability for deduction of tax rests on the assessee.

residents and therefore, they are the recipients and receipts by

them is subject to deduction of tax at source.

them as advance and to some of them on various letters issued

by the assessee. Therefore, the fact of the payment is also proved.

carrying on of certain work by them. The assessee is also

specifically form for the object of preparation for and holding the

South Asian Federation Winter Games in February 2009 allotted

to Indian Olympic Association. The functions of the assessee are

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18 to collect funds through grants for furtherance of the aims and

objectives of the society. Assessee has stated that grants are

received by the assessee and in turn, it are disbursed to the

various recipients who were appointed as executing agencies to

get the work done through contractors. Further, those agencies

have also submitted their utilization certificate for the amount

utilized by them. Based on the above fact it is apparent that

assessee is an implementing agency on behalf of Indian Olympic

Association for preparation of these games. No doubt, the

assessee has received the funds as sponsorship and grants but

the responsibility is on the assessee to execute the entire

infrastructure for the games. Though the contractor may be

identified and engaged by the other organization, however, the

implementation and utilization is the sole responsibility of the

assessee. Otherwise, there is no other reason for the formation of

the above society. The society itself was registered on

06.02.2008. Further, the payments to above companies/ PSu

have been made by the assessee. Therefore, it is clear that

assessee is the person responsible for payments of sums to those

PSUs. In view of this it is apparent that the contract is between

the recipient of the income and the assessee. Hence, according to

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19 us the assessee is responsible for TDS u/s 194C of the act on

payment made to these parties.

distribution to these parties does not exclude the assessee from

the liability for deduction of tax at source u/s 194 C of the act,

as the assessee is responsible for making payments to these

parties and in fact, undeniably assessee has made the payments

and obtained utilization certificates.

source that recipient of the income have onward distributed the

work to the sub contractors and recipient of the income have in

turn deducted the tax at source on payment made by them to

those sub- contractors. According to the provision of 194C of the

Act even, the contractor is also required to deduct tax at source

on payment made to their sub contractors.

are subject to tax deduction at source u/s 194C of the Act and

assessee is liable to deduct tax at source u/s 194C of the Act.

Therefore, to this extent we uphold the order of lower

authorities.

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

20 25. Next clinching, alternative argument made by the assessee is

that all the recipient of the income has already confirmed that

they have received the grant. Such certificates are placed in the

paper book from page No. 126 to 179 of the paper book. We have

perused the same. The argument of the assessee is that if tax is

recovered from the assessee it becomes refundable in the hands

of the recipient. To mitigate such an impact the proviso has been

added u/s 201 of the Act w.e.f. 01.07.2012 which provides that

any person who fails to deduct tax in accordance with chapter

XVII of the Act, shall not be deemed to be an ‘assessee in default’

on fulfillment of certain condition. The above amendment is on

similar line as argued by the appellant. Though the above

amendment has come in to effect from /7/2012 but

Honourable Delhi high court has held in Ansal Landmark

Townships Limited in 161 /2015 held that

“11. The first proviso to Section 210 (1) of the Act has been

inserted to benefit the Assessee. It also states that where a

person fails to deduct tax at source on the sum paid to a

resident or on the sum credited to the account of a resident

such person shall not be deemed to be an assessee in

default in respect of such tax if such resident has furnished

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

21 his return of income under Section 139 of the Act. No doubt,

there is a mandatory requirement under Section 201 to

deduct tax at source under certain contingencies, but the

intention of the legislature is not to treat the Assessee as a

person in default subject to the fulfillment of the conditions

as stipulated in the first proviso to Section 201(1). The

insertion of the second proviso to Section 40(a) (ia) also

requires to be viewed in the same manner.”

Therefore respectfully following the decision of Honourable Delhi

High court we set aside the order u/s 201 of the Act with a

direction that assessee may submit the requisite prescribed

detail in specified manner before the ld Assessing Officer and

then ld AO may decide the issue and, if found in accordance with

the law, shall not treat the assessee in default u/s 201 of the Act.

With respect to the interest u/s 201(1A) of the Act similar proviso

is also added and AO may work out, based on the details

furnished by the assessee, appropriate interest in accordance

with law. In view of this ground No. 4 and 5 of the appeal is

allowed accordingly.

(STC), it is apparent that the equipment have been purchased by

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22 the assessee as identified by it through STC. The STC has

incurred certain expenditure with respect to import of those

goods. The assessee has placed correspondence at page No. 122

and 123 of the paper book. According to that correspondence,

the state trading corporation has facilitated import of certain

equipment for the assessee and for clearance of the equipment

has incurred certain expenditure. The ld CIT (A) has held that no

tax is required to be deducted on the above sum. On careful

consideration of the orders of the lower authorities, the STC had

undertaken to import and supply the equipment as per the

requirement of the assessee. For the purpose of import of these

goods, the STC incurred certain expenditure such as installation

commissioning charges, handling charges, insurance, and other

payments. In this case, it is not the claim of the assessee that

STC has supplied the goods. In fact, STC has arranged for the

import of the goods as per requirement of the assessee. In view of

this, it is apparent that assessee has given work to the STC for

import of the material. Hence, according to us it is apparent that

such payment falls under the provisions of section 194C(3) of the

Act and tax is required to be deducted on the basis of the invoice

value stated therein. The invoices are not place before us. Hence,

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23 we set aside this matter back to the file of the ld Assessing

Officer with a direction to assessee to produce the bills of STC etc

before ld AO who will examine them. If the invoice value shows

the value of the material separately then assessee is required to

deduct tax at source only on the invoice value excluding the

value of material. Findings given by us with respect to the

payment to the PSU with respect to Proviso to section 201 shall

also apply mutatis mutandis to this payment also. Accordingly,

the ground no. 2 of the appeal of the revenue is set aside to the

file of the ld AO.

2009-10 and 2010-11 on the issue of demands raised on the

assessee by order u/s 201(1) and 201(1A) of the Act for both the

years are disposed off with above direction.

the CIT(A), Dehradun dated 24.12.2014 passed for AY 2010-11

wherein, the penalty u/s 271C of the Act of Rs. 1152461/- levied

by the JCIT, TDS, Dehradun vide order dated 25.03.2013 is

confirmed.

made is not subject to TDS with respect to the PSU and STC. It

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

24 was stated that there was a reasonable cause for non-deduction

of tax at source. Hence, no penalty can be levied.

the orders of the lower authorities. On looking to the facts of the

case as discussed by us in appeal of the assessee and revenue in

201(1) and 201(1A) proceedings above, we find that the belief of

the assessee is bonafide and failure to deduct tax at source u/s

194C of the Act is for a reasonable cause. The ld Assessing

Officer could not show any contemptuous conduct on part of the

assessee for non-deduction of tax at source. There could also not

be any reason for non-deduction as assessee has made most of

the payments to the public sector undertaking. The Hon'ble

Supreme Court in the case of CIT Vs. Bank of Nova Scotia in 380

ITR 550 has approved the decision of the Hon'ble Delhi High

Court wherein, it has been held that it is necessary to establish

‘contumacious conduct’ on the part of the assessee for failure to

deduct tax at source for levy of penalty u/s 271C of the act. In

the present case, all the recipients have also furnished a

certificate that they have received the payment. In view of this,

we reverse the order of the ld CIT (A) confirming the levy of the

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

25 penalty of Rs. 1152461/- u/s 271C of the Act in absence of any

finding to show contumacious conduct on the part of the

assessee. Ld OA id directed to delete the penalty-levied u/s 271C

of the act. Accordingly, appeal of the assessee in ITA No.

1576/Del/2015 for AY 2010-11 is allowed.

are partly allowed and ITA No. 798 and 799/Del/2013 filed by

the AO are partly allowed. ITA No. 1576/Del/2015 for AY 2010-

11 filed by the assessee is allowed. Hence, all five appeals are

disposed off.

Order pronounced in the open court on 15/10/2018.

Sd/- Sd/-

(AMIT SHUKLA) (PRASHANT MAHARISHI) JUDICIAL MEMBER ACCOUNTANT MEMBER

Dated:15/10/2018 A K Keot Copy forwarded to

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

Date of dictation Date on which the typed draft is placed before the dictating member Date on which the typed draft is placed before the other member Date on which the approved draft comes to the Sr. PS/ PS Date on which the fair order is placed before the dictating member for pronouncement Date on which the fair order comes back to the Sr. PS/ PS Date on which the final order is uploaded on the website of ITAT date on which the file goes to the Bench Clerk Date on which the file goes to the Head Clerk The date on which the file goes to the Assistant Registrar for signature on the order Date of dispatch of the order

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,

626-627-798-799-Del-2013 and 1576-Del-2015-The Joint Secretary Organizing Committee for Winter Games,