MOINODDIN S/O RAHIMUDDIN,AJMER vs. ITO, AJMER

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR Jh dqy Hkkjr] U;kf;d lnL; ,oa Jh foØe flag ;kno] ys[kk lnL; ds le{k BEFORE: SHRI KUL BHARAT, JM & SHRI VIKRAM SINGH YADAV, AM vk;dj vihy la-@ITA No. 380/JP/2014 fu/kZkj.k o"kZ@Assessment Year : 2008-09 cuke Shir Moinoddin S/o Rahimuddin, The ITO, Ward 1(1), Ajmer Vs. 86/3, Kamela Mohalla, Dargah Bazar, Ajmer LFkk;h ys[kk la-@thvkbZvkj la-@PAN No. AXUPM6079R vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@Assessee by : Shri Subhash Porwal (CA) jktLo dh vksj ls@Revenue by : Shri Ajay Malik (Addl.CIT) lquokbZ dh rkjh[k@Date of Hearing : 04/05/2017 ?kks"k.kk dh rkjh[k@Date of Pronouncement: 22/05/2017. vkns'k@ORDER PER SHRI VIKRAM SINGH YADAV, A.M.

This is an appeal filed by the assessee against the order of CIT(A), Ajmer dated 14.03.2014 for A.Y.2008-09 wherein the assessee has taken following grounds of appeal: “(1) In not granting the expenditure incurred on sale of transfer of Rs. 1,58,983/- u/sec. 48. (2) Non granting the fair market value of property as on 01.04.1981 as per registered valuer’s. (3) Non granting the benefit of “Cost of Construction +Improvement” of Rs. 3,50,000.00 incurred by assessee after purchase of property on 25.07.2008 u/sec. 54 (Besides purchase cost).

ITA No.380/JP/2014 Shri Moinoddin vs.ITO Ward 1(1), Ajmer

(4) Confirming the income of Rs. 5,80,988.00 as income from other sources being income from pan shop.”

prosecution by the Coordinate Bench vide its order dated 30.10.2015.

Subsequently, the Coordinate Bench withdrawn the said order while disposing

off the miscellaneous application filed by the assessee and the earlier ex-

parte order dated 30.10.2015 was recalled by the Coordinate Bench by its

order dated 27.5.2016. Now the matter has come up for hearing before this

Bench.

(i) As regarding the sale consideration adopted by the AO at Rs. 47,94,226 as per provision of Sec. 50C of the I.T. Act, the assessee has no objection as per the submission. Hence the first ground of appeal is dismissed.

(ii) As regarding the transfer expenses of Rs. 1,58,983 claimed by the assessee, assessee has submitted that assessee paid the dalali and commission of Rs. 1,50,000 to the broker and Rs. 8,983 as other petty expenses and has submitted receipts of two persons for the dalali of Rs. 1,50,000. However, no such documents were produced before the AO in spite of repeated opportunities given as mentioned in the assessment order. During

ITA No.380/JP/2014 Shri Moinoddin vs.ITO Ward 1(1), Ajmer appeal, assessee contended that he was ill at that time. However, no supporting documents in this regard have been submitted. So the above additional evidences are not admitted. Accordingly, disallowance on this account made by the AO is confirmed.

(iii) As regarding fair market value of the asset as on 01.04.1981, assessee has claimed the same to be Rs. 3,00,050/- based on the valuation report. However, the AO has pointed out that as per the registered partition deed obtained by the AO from the Sub Registrar, the fair market value of the property as on 25.04.1988 was Rs. 35,000/- only which has been mentioned in the partition deed. As such, there cannot be higher value as on 01.04.1981.

The assessee’s claim that partition deed speaks about only construction and not land and common area is not valid as it is apparent from the partition deed that the market value of the said property has been mentioned by the owners themselves as Rs. 35,000 for the whole of the property and stamp duty has been paid accordingly. In such a case, assessee’s claim that the value of the property as on 01.04.1981 was Rs. 3,00,350 is not sustainable.

Further, the assessee while in the original proceedings had claimed the fair market value as on 01.04.1981 at Rs. 3,00,350 while now assessee has revised the same to Rs. 2,55,587 as per the revised valuation report. However, in the revised valuation report, it has been mentioned that ground floor, first floor and balcony was existing as on 01.04.1981 but as per partition deed dated 04.04.1988, no such construction on first floor and balcony has been mentioned. Accordingly, no reliance can be placed on the said valuation report for value as on 01.04.1981.

ITA No.380/JP/2014 Shri Moinoddin vs.ITO Ward 1(1), Ajmer Further, assessee has only half share in the property which was valued at Rs. 35,000/- at the time of partition as discussed above. The assessee was show cause as to why the fair market value of assessee’s share at the time of partition should not be taken at Rs. 17,500 to which assessee has reiterated the earlier contentions placing reliance on the valuation report which has already rejected as discussed above.

In view of the above discussion, the AO had the reasonable basis for adopting the fair market value at Rs. 35,000 as on 25.04.1988 based on the partition deed and allowing the indexation for the later period. However, as pointed out earlier, the assessee’s has only half share in the property. So fair market value at the time of partition should be taken at Rs. 17,500 for the purpose of computation of capital gains.

(v) The assessee has claimed deduction u/s 54 of the I.T. Act for the investment in the house property of Rs. 30,50,000/-. During appeal, assessee has submitted that on 25.07.2008, the assessee has purchased a house property No. 847/23 on 25.07.2008 at Kamela Mohalla, Harijan Basti for Rs. 20,00,000. The said document regarding purchase of the house is registered document so it is considered relevant for claim of deduction u/s 54 of the I.T. Act. During appeal, the AO has examined the document and stated it being a registered document, may be considered for the claim of the assessee.

The assessee has claimed the deduction u/s 54 of the I.T. Act stating that the property sold was the ancestral property which was used for the residence of the assessee which is evident from the partition deed as well as details of the property as mentioned in the partition deed as well as the sale deed. The said property was a residential house and income from the same was chargeable under the head ‘income from house property’. The assessee’s contentions in

ITA No.380/JP/2014 Shri Moinoddin vs.ITO Ward 1(1), Ajmer this regard are acceptable in view of the provision of the Sec. 54 of the I.T. Act.

The assessee has purchased a house property No. 847/23 on 25.07.2008 at Kamela Mohalla, Harijan Basti for Rs. 20,00,000/- in name of his wife, Smt. Zubeda Bibi. The assessee has explained that the said property was purchased from the sale proceeds of the original asset and Smt. Zubeda Bini is a housewife having no source of income. It is noted that in the case of DIT International Taxation vs. Mrs. Jennifer Bhide 349 ITR 80 (Karn) replied upon by the appellant, it has held as under: (headnote)

“Capital gains- Exemption under ss. 54/54EC-Scope and allowability- For purposes of ss. 54/54EC, it is not necessary that purchase of property or investment in specified bonds must be in the name of assessee only- Assessee, out of sale proceeds of residential property purchasing another residential property and specified bonds, exemption under ss. 54/54EC could not be denied to her to the extent of 50 per cent on the ground that new property and bonds were purchased in the names of assessee and her husband when admittedly no consideration followed from the husband.”

In view of above facts, the claim of deduction u/s 54 for the purchase consideration of Rs. 20,00,000/- is allowable subject to discussion below.

It is seen that the new house property purchased by the assess is consist partly of the shops and is partly residential as per the purchase deed, details of which are as under:

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Accordingly, for the purpose of Sec. 54, the AO is directed to allow deduction u/s 54 proportionately in respect of residential portion of the property purchased by the assessee.

The AO is directed to compute the taxable capital gains accordingly.”

“5.3 I have considered the contentions of the appellant as well as assessment order. It is seen that in the original proceedings, assessee had claimed the dividend income of Rs. 2 lac and other income of Rs. 3,80,988.

Then during assessment proceedings, assessee filed a computation of income showing income of Rs. 1,80,988 from pan shop and income of Rs. 4,00,000 from the loans given to his sons.

The assessee has not been able to give any evidence regarding income from pan shop as well the expenses claimed by the assessee.

During appeal assessee himself has accepted that disallowance of depreciation claimed of Rs. 11.40 lacs is justified.

ITA No.380/JP/2014 Shri Moinoddin vs.ITO Ward 1(1), Ajmer It is seen that the assessee has being changing his stand regarding the source of income of Rs. 5,80,988 as is evident from record. The findings of the AO have not been controverted in any manner. In view of above discussion, the addition made by the AO of 5,80,988 as income from other sources is confirmed.”

(1) Not granting the expenditure incurred on sale of transfer of Rs. 1,58,983.00 u/sec. 48.The A.O. noticed during assessment proceedings that assessee has sold property bearing AMC No. 3/144=AMC 7/408= 14/403 situated at Pahul Gali, Nala Bazar, Ajmer on 30.11.2007 for sale consideration of Rs. 38,00,000.00. The value of this property was adopted for registration purposes at Rs. 47,94,226.00 (In term of Section 50C)

The A.O. while applying the provisions of section 50C of Income Tax Act, 1961 has thus taken the deemed sales value for calculating the Long Term Capital Gain at Rs. 47,94,226.00 instead of actual sales consideration at Rs. 38,00,000.00. We have no objection to this extent.

However, the AO was duty bound in terms of section 48 of Income Tax Act, 1961 to give the benefit of deduction from the full value of consideration (Deemed Consideration in terms of section 50C) received or accruing as a result of the transfer of the capital asset of the following amounts namely:-

(i) Expenditure incurred wholly and exclusively in connection with such transfer.

(ii) The cost of acquisition of the asset and the cost of any improvement thereto.

ITA No.380/JP/2014 Shri Moinoddin vs.ITO Ward 1(1), Ajmer

Assessee while filing the return of income has claimed deduction u/sec. 48 a sum of Rs. 1,58,983.00 as expenditure incurred wholly and exclusively in connection with such transfer.

It is not the amount of stamp duty or registration expenses paid by purchaser on registration of document as alleged by A.O. in his order, but it is amount paid as Dalali & Commission of Rs. 1,50,000.00 on such sale to broker and Rs. 8,983.00 is for petty expenses like amount paid to vakil, amount paid for NOC from Municipality & amount incurred on petty repairs of proposed sale portion. It is requested to kindly give the credit for same in term of section 48 of Income Tax Act, 1961.

Accordingly the net sales consideration as taken by A.O. at Rs. 47,94,226.00 should have been taken at Rs. 46,35,243.00 ( 47,94,226.00-1,58,983) by way of granting the benefit of section 48 of Income Tax Act, 1961. Needful evidences as enclosed.

The Ld. CIT(A) simply because the evidences for Dalali & Commission for Rs. 1,50,000.00 to the broker and Rs. 8,983.00 amount incurred for petty expenses and though evidence submitted before him but not before A.O. hence disallowed to grant the credit for sameconsidering them as additional evidences.Whereas due to ill health of assessee, the said documents though were not submitted to AO but were claimed in return & the Ld. CIT(A) was duty bound to accept the same or could have refer to A.O. for re-verification for cause of justice.

It is again to bring to your notice that assessee being not aware of legal procedure has even admitted the value adopted u/sec. 50C of sale; whereas

ITA No.380/JP/2014 Shri Moinoddin vs.ITO Ward 1(1), Ajmer u/sec. 50C(2) the assessee had right to get referred the said value to “Valuation Officer” for actual valuation the assessee now request for same for cause of justice.It is requested to consider the facts & grant due credit in terms of section 48 & also allow the assessee to get refer the valuation in terms of section 50C(2) of Income Tax Act, 1961 to DVO.

(2) Non granting the fair market value of property as on 01.04.1981 as per registered valuer’s. In this regard, it was submitted as under:

(1) That the property was acquired by Late Rahimuddin S/o Kadarbux father of assessee on 27.01.1959 for Rs. 4500/- Shri Rahimuddin expired after that. (2) That later this property was distributed by legal heirs (Sons) (a) Shamshuddin (Deceased) through wife Hasina Bano & Aminuddin (son) &(b) Moniuddin & family by way of family distribution deed dated 23.04.1988.

(3) Section 49(1) speaks about “cost with reference to certain modes of acquisition” & clause (iii) to such section also express that where the capital asset became the property of the assessee-

Section 49(1)(iii)— (a) By succession, inheritance or devolution, or (b) On any distribution of assets on the dissolution of a firm, body of individuals, or other association of persons, where such dissolution had taken place at any time before the 1st day of April, 1987, or (c) On any distribution of assets on the liquidation of a company, or (d) Under a transfer to a revocable or an irrevocable trust, or

ITA No.380/JP/2014 Shri Moinoddin vs.ITO Ward 1(1), Ajmer (e) Under any such transfer as is referred to in clause (iv) [ or clause (v)] [or clause (vi)] [ or clause (via)] [or clause viaa)] [or clause vica) or [clause (vicb)] or clause (xiiib) of section 47]; The cost of acquisition of the asset shall be deemed to be the cast for which the previous owner of the property acquired it, as increased by the cost of any improvement of the assets incurred or borne by the previous owner or the assessee, as the case may be.

Explanation—In this the expression “previous owner of the property” in relation to any capital asset owned by an assessee mean the last previous owner of the capital asset who acquired it by a mode of acquisition other than that referred to in clause (i) or clause (ii) or clause (iii) [ or clause (vi) of this [ sub section].

(4) Section 55 speaks of “cost of acquisition” “adjusted” cost of improvement” (1) Sub section (2) to section 55 speaks of “In relation to any other capital asset— (i) Where the capital asset became the property of the previous owner of the assessee before the 1st day of April, 1981 means all expenditure of a capital nature incurred in making any additions or alternations to the capital asset on or after the said date by the previous owner or the assessee, and

(ii) In any other case, means all expenditure of a capital nature incurred in making any additions or alternations to the capital asset by the assessee after it became his property, and, where the capital asset became the property of the assessee by any of the modes specified in sub-section (1) of section 49, by the previous owner,

ITA No.380/JP/2014 Shri Moinoddin vs.ITO Ward 1(1), Ajmer But does not include any expenditure which is deductible in computing the income chargeable under the head “Interest On securities”, “Income form House Property”, “profit and gains of business or profession”, Or “Income From Other Sources”, and the expression “improvement “shall be construed accordingly.

Further section 55 (2) speaks for the purpose of section 48 and 49 “cost of acquisition” Sub section (ab)(b) to section 55(2) say— (1) In relation to any other capital asset- (i) Where the capital asset became the property of the assessee before the 1st day of April 1981,means the cost of acquisition of the asset to the assessee or the fair market value of the asset on the 1st days of April, 1981 at the option of the assessee. (ii) where the capital asset became the property of the assessee by any of the modes specified in sub section (1) of section 49, and the capital asset became the property of the previous owner before the 1st day of April, 1981 means the cost of the capital asset to the previous owner or the fair market value of the asset on the 1st day of April, 1981 at the option of the assessee.

Thus the Assessee has all right to replace the F.M.V. as on 01.04.1981 being cost of acquisition for indexation.

The A.O. has relied on the document “partition deed” dated 25.04.1988 (Page-5) where the Sub-Registrar-1, Ajmer has substituted the market value of the proportionate property at Rs. 35,000/- & instead accepting the FMV as on 01.04.1981 at registered valuer’s value at Rs. 3,00,350/- (As copy enclosed) has applied this value Rs. 35,000/- for cost indexation, which is not justified for the reason below:-

ITA No.380/JP/2014 Shri Moinoddin vs.ITO Ward 1(1), Ajmer

(i) That in terms of section 49(i)(iii) & section 55(2) as discussed by the A.O. is duty bound to accept the F.M.V. as on 01.04.1981 in terms of provision of law.

(ii) That the partition deed only speaks about value of construction partitioned & not land & common area. Further the value as adopted by sub-Registrar is depreciated value of construction over the life of (Age of) property. Further in the year 1988 when Sub-Registrar has adopted the estimated value is not based on DLC values (District level Committee values) since there was no DLC in law nor any provisions of section 50C were applicable thus A.O. was duty bound to accept the registered Valuer’s report to ascertain the F.M.V. as on 01.04.1981, any doubt if there, the A.O. was duty bound to refer the matter u/sec. 55A to Valuation Officer. The A.O. is not a technical person & cannot have it’s own concept or estimates & is duty bound as per provisions of law.

(iii) Further on going through the details of the property partitioned v/s the property sold there are vast differences in measurements e.g. The partition deed do not mention the construction of hall & others on second floor, whereas the sale deed of Rs. 38,00,000/- states that the hall & bath latrine, terrace etc is also constructed on this second floor, probably the assessee has not declared these facts property to Registered Valuer & due to ignorance of facts considered this portion in his report to as certain the F.M.V. as on 01.04.1981.

Now we are enclosing the revised valuation report of registered Valuer dated 09.02.2009 after incorporating all these facts & request your honour to direct the A.O. to consider accordingly.

ITA No.380/JP/2014 Shri Moinoddin vs.ITO Ward 1(1), Ajmer Accordingly the CII (Cost Inflation Index) value should be calculated as under:- (a) CII value of cost of acquisition 255587/-x551 being F.M.V. as on 01.04.1981 as per 100 =14,08,284/- revised valuation report. (b) CII Value of construction made on or 102380x551 after the partition deed dated 23.04.1988 161 =3,50,381/- (as per assessee it was constructed in the financial year 1988-89) ........................... (c) Total CII Value 17,58,665/-

(4) CONFIRMING THE INCOME OF Rs. 5,80,988.00 AS INCOME FROM OHTER SOURCES BEING INCOME FROM PAN SHOP.

Thus AO observed that assessee has shown income from Pan Shop Rs. 1,80,988/- besides other receipts and expenses, details below:-

INCOME FROM OTHER SOURCES Income from Pan shop 180988 Loan to elder son Sh. Salamuddin (without interest) 200000 Loan to younder son Sh. Alaudding (without interest) 200000 Shop Rent -3000 Raw material purchased -132988 Salary to helper ( Rs. 85/ per day) -30600 Misc Exp. -23984 Depreciation as per chart 57(II) -1140000 Total -749584

Considering Rs. 2,00,000/- each as loan to elder son Salamuddin and younger son Alauddin as “Income”. Similarly depreciation claimed on “fixed assets” being “property sold” Rs. 11,40,000/- has also been considered as disallowed.

ITA No.380/JP/2014 Shri Moinoddin vs.ITO Ward 1(1), Ajmer Further expenses of Pan shop Rs. 1,90,572/- has also been considered as disallowed for non production of vouchers and evidences and thus by disallowing all such expenses the AO has finally considered Pan Shop income at Rs. 5,80,988/-; whereas the facts are:-

(a) That any loan ( interest free) to son as paid cannot be considered as “income” being capital payments and are not “Revenue receipts” and thus making addition thereof is not as per intention of law or is justified.

(b) That disallowing of depreciation claimed Rs. 11,40,000/- on property used for Pan Shop but sold during the year is justified; since any asset when is not in existence as on closing of year.

But also disallowing expenses related to Pan Shop for raw material purchased; salary to helper and misc expenses should have been considered in “Business expediency” even though no vouchers produced. Thus a reasonable estimation should have been made by AO before deciding the issue.

5.1 As part of the ground no. 1 relating to expenditure allowable under section 48 of the Act, in its contentions, in respect of deemed sale consideration adopted by the AO in terms of section 50C, the ld AR has also requested for reference to valuation under section 50C(2) of the Act stating

ITA No.380/JP/2014 Shri Moinoddin vs.ITO Ward 1(1), Ajmer the appellant being not aware of the legal provisions has admitted the same but he has a right which he wishes to exercise in terms of section 50C(2) of the Act. Firstly, there is no specific ground which has been taken by the appellant before us in this regard. Secondly, the appellant had sufficient opportunity to take up the said ground before the ld CIT(A) and interestingly, before the ld CIT(A) who exercises the co-terminus powers with that of AO, the appellant has stated before him that he has no objection to the adoption of value as done by the AO under section 50C of the Act. And now, again the said issue has been raised before us as part of its contentions and not by way of a specific ground. In our view, the said inconsistent stand and approach of the appellant is not acceptable and cannot be acted upon. Once the appellant has accepted and conceded on a ground before a lower authority, in our view, it would be incorrect on part of the appellant to raise this contention again and expect the Bench to decide the same. In the result, we are unable to accede to this contention of the appellant to refer the matter to valuation officer under section 50C(2) of the Act. 5.2 Now, coming to ground no. 2 regarding non granting of fair market value of property as on 1.4.1981 as per registered valuer report, it is not disputed that the subject property was acquired by assessee as part of family distribution deed dated 23.04.1988 at Nil consideration and thus, in terms of section 49(1)(iii), the cost in the hands of the previous owner shall be considered for determining the cost of acquisition in the hands of the assessee. The previous owner has acquired the subject property prior to 1.4.1981 and thus, the cost of acquisition shall be the cost to the previous owner or the fair market value as on 1.4.1981 at the option of the assessee. The assessee has exercised his option and in support, has submitted a valuation report to determine the fair market value as on 1.4.1981. The AO has relied upon the partition deed dated 23.04.1988 and there is no specific finding as why the valuation report submitted by the appellant is not

ITA No.380/JP/2014 Shri Moinoddin vs.ITO Ward 1(1), Ajmer acceptable. The matter is accordingly remanded back to the file of the AO to examine the valuation report submitted by the appellant and examine the matter a fresh.

5.3 Regarding ground no. 3 for non grant of cost of improvement of Rs 3,50,000 claimed to be incurred by the assessee under section 54, we find that there is specific contention taken by the assessee either before the AO or ld CIT(A). Further, there is nothing on record to adjudiciate on the matter and hence the said ground is dismissed in limine.

5.4 Regarding ground no. 4 relating to income from pan shop considered as income from other sources, the AO observed that the assessee has declared totla income of Rs 580,988 as income from other sources in his return of income and thereafter, during the assessment proceedings, he brought the story of running the pan shop but could not substantiate his said contentions regarding running of pan shop with any evidences. During the appellant proceedings, the said findings of the AO remain uncontroverted. There is nothing further that has been brought to our knowledge to dispute the above findings. In light of that, this ground of appeal is dismissed.

In the result, the appeal of the assessee is partly allowed for statistical purposes.

Order pronounced in the open court on 22/05/2017. Sd/- Sd/- (KUL BHARAT) (VIKRAM SINGH YADAV) U;kf;d lnL;@Judicial Member ys[kk lnL;@Accountant Member

Jaipur Dated:- 22/05/2017 *Ganesh आदेश की प्रतिलिपि अग्रेषित@ब्वचल वf जीम वतकमत वितूंतकमक जवरू vihykFkhZ@The Appellant- Shir Moinoddin S/o Rahimuddin, 86/3, Ajmer 1. izR;FkhZ@ The Respondent- ITO, Ward 1(1), Ajmer. 2. 16

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सहायक पंजीकार@ Aेेपेजंदज. त्महपेजतंत