RAJASTHAN EXPLOSIVES & CHEMICALS LTD.,NEW DELHI vs. DCIT, BHARATPUR

to the assessment year 2000-01.

convenience and brevity, a common order is being passed.

sole ground of appeal taken by the revenue is reproduced as under:-

(i) That the Commissioner of Income Tax (Appeals), Alwar has erred in law as well as on the facts and circumstances of the case in deleting the addition of Rs. 55,10,113/- made by the A.O. by disallowing the claim of depreciation on Plant and machinery and other assets due to closure of factory.”

3.1 The only issue involved in this appeal is against deleting the addition

of Rs. 55,10,113/- made by the Assessing Officer by disallowing the claim

of depreciation on plant and machinery and other assets due to closure of

factory.

Assessing Officer show caused the assessee and asked as to why the

depreciation claimed by it may not be disallowed as the company was

ITA 842 & 799/JP/2013_ 3 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

closed from 03/6/1998 to 19/06/2000 i.e. the whole year under

consideration and he disallowed the claim of the assessee.

who after considering the submissions deleted the addition by observing

as under:-

“2. The Company remained closed during the period from 03.06.1998 to 19.06.2000 and the company was under the purview of Honorable BIFR. The Honorable BIFR sanctioned the Scheme on 8.5.2000 and changed the management from Mr. Rajesh Jain to Capt K S Solanki Group. During the closure period the Company was under the control and charge of M/s Rajasthan Industrial Investment Corporation Ltd. (RIICO) Jaipur (Rajasthan) as per the directives of BIFR. 3. The learned assessing officer has disallowed depreciation of Rs. 55,10,113/- due to closure of factory. The Learned Assessing Officer did not consider the circumstances and reasons for the closure of the factory. He also did not consider the previous back ground of the Company. He also did not consider the state of the machineries and other fixed assets of the Company. We submit that the assessee is quite old Company and it has commenced its operations in the year 1980. The Company had been using its plant and machineries and other fixed assets since inception. The Company could not utilize the fixed assets temporary for the period from 03.06.1998 to 19.06.2000 due to closure of its factory for the want of working capital etc. The fixed assets of the Company always remained in the factory and ready for use in the closure period also. The fixed assets could not be utilized and the

ITA 842 & 799/JP/2013_ 4 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

circumstances were beyond the control of management. As the company was sick and commenced again as per the directives of the Honorable BIFR. The assets were always in passive use. We refer to the judgment of Hon’ble Delhi High Court in the case Commissioner of Income Tax V. Lakshmi Sugar Mills Limited (2012) Taxmann.Com 41 (Delhi). The judgment is enclosed in Annexure-2. The Honorable High Court has allowed the depreciation for the closure period of the factory. The circumstances of this case are quite similar to our case. Lakshni Sugar Mills Limited was also closed for the years 2002-03, 2005-06 and 2006-07 and the company became sick. The depreciation was allowed for the closure periods. Thus in this circumstances we therefore pray before your honor to kindly delete the addition made of Rs. 55,10,113/- on account of depreciation. 4.3 I have considered the AOs order and submissions made by the AR and the case laws cited by the AR and find force in the arguments given by the appellant. AO has made disallowance on the ground that the factory was closed during the year and also in the preceding year and the machinery was not fit for use. It is stated by the AR that factory had to be closed from 03.06.1998 to 19.06.2010 on account of liquidity problems and the matter was pending before BIFR for revival of the business. Further, the AR has relied upon the judgment of Hon’ble Delhi High Court in the case of CIT Vs. Laxmi Sugar Mills Ltd. (2012) Taxman.Com 41(Delhi). Depreciation is an allowance which has to be given, even if, the factory has been closed for some reason, as it depreciates both by usage and with the passage of time. In view of these facts, I find that the AO was not justified in not allowing the depreciation

ITA 842 & 799/JP/2013_ 5 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

on the plant and machinery. Accordingly, I delete the addition of Rs.55, 10,113 made by the AO under this head.”

available on the record. We find that the ld. Sr.DR was not able to

controvert the finding given by the ld. CIT(A). The assessee’s factory was

closed on the account of liquidity problem and the matter was pending

before the BIFR for revival of the business. The Hon’ble Delhi High court in

the case of CIT Vs. Laxmi Sugar Mills Ltd. (supra) has held as under:-

“Assessee claimed depreciation in respect of machineries installed in its sugar mill - Assessing Officer disallowed claim of depreciation on ground that sugar mill had stopped functioning and was not in operation - Lower authorities found that mill remained closed because of fact that company had become sick due to lack of fund and efforts were made by company for its revival and restarting of mill and it was, subsequently, reopened on 19-12-2006 when a scheme of rehabilitation was sanctioned by BIFR and since that date, mill was working and same plant and machinery were being used in manufacturing activity of sugar - It was, therefore, held that in intervening period, plant was ready for use throughout and same could not be used for reasons beyond control of assessee and hence, there was passive user of plant and therefore, in view of facts that above claim of assessee regarding depreciation should be allowed - Whether in view of that facts plant and machinery were kept ready for use with intention and desire to make it operational as soon as liquid funds were made available and that factory was ultimately made operational, lower authorities rightly allowed depreciation to assessee - Held, yes [In favour of assessee].”

ITA 842 & 799/JP/2013_ 6 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

In view of the above facts and circumstances, we sustain the order of the

ld. CIT(A) and accordingly, the ground raised in the revenue’s appeal

stands dismissed.

appeal, the assessee has raised following grounds of appeal.

(i) Action of CIT(A) in confirming the action of the A.O. of disallowance of writing of Sundry debtors M/S Nam -Nam Dhaka of Rs. 58,80,646/- is unjust, illegal, arbitrary and against the facts and circumstances of the case. This amount have been written off since it was not recoverable considering the rehabilitation scheme sanctioned by Honorable BIFR dated 08/05/2000.

(ii) Action of CIT(A) in confirming the action of the A.O. of disallowance of write off of Loans and advances of Rs. 1,47,62,069/- is unjust, illegal, arbitrary and against the facts and circumstances of the case. These amounts have been written off considering the rehabilitation scheme sanctioned by Honorable BIFR dated 08/05/2000.

(iii) Action of CIT (A) in confirming the action of the A.O. of disallowance of write off of fixed assets of Rs. 13,67,295/- is unjust, illegal, arbitrary and against the facts and circumstances of the case. These assets were found missing during the course of taking over of the operation of the company by the new management and company has written off these assets.

(iv) Action of CIT (A) in confirming the action of the A.O. of disallowance of interest amount of Rs. 35,00,000/- is unjust, illegal, arbitrary and against the facts and circumstances of the case. This interest forms part of total interest of Rs.

ITA 842 & 799/JP/2013_ 7 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

65,00,000/- which has been provided, as per the direction given by the honorable BIFR in scheme sanctioned on dated 08/05/2000, on the various credit facility availed by the company from the bankers.

58,80,646/- on account of disallowance of writing off sundry creditors M/s

Nam Nam Dhaka. During the year the assessee write off Rs. 58,80,646/- in

the name of M/s Nam Nam Dhaka. The assessee was asked to produce

approval/permission of RBI to write off this amount. The assessee had not

filed approval in this regard. The assessee applied to RBI for permission on

20/01/2003 and therefore, the write off was not allowed.

8.1 The ld CIT(A) confirmed the action of the Assessing Officer by

holding that the case laws relied upon were different from the facts of the

assessee and not applicable in assessee’s case. He also noted that the

Hon'ble Supreme Court Constitution bench in its order passed in 2012,

wherein it was held that a provision made by the NBFCs in their books of

accounts in accordance with the instructions/guidelines issued by the RBI

for NPAs, would not be allowable as a deduction under the Income Tax Act

and therefore, the ld. CIT(A) confirmed the action of the Assessing Officer.

assessee has relied on the decision of the ITAT ‘A’ Bench, Bangalore in the

ITA 842 & 799/JP/2013_ 8 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

case of Adea International Pvt. Ltd. Vs. ACIT in ITA No. 565/Bang/2010

wherein the Coordinate Bench of the Tribunal has held as under:-

“8. We have heard the rival submissions and perused the paper book filed by the assessee along with the copies of the decided cases. It is not disputed that the amount of Rs.1,94,99,064 were the bills outstanding for realization from export turnover. The only grouse of the Revenue is that they cannot be claimed as bad debts since the assessee had not obtained the requisite approval from the appropriate authority as per the Foreign Exchange Management Act. The assessee has relied on the case Southern Technologies Ltd. v. JCIT 320 ITR 577 (SC), wherein it was held that the RBI directions of 1998 are merely prudential norms regarding presentation of non-performing assets provision in the balance sheet; they do not touch upon the nature of expense to be decided by the Assessing Officer in the assessment proceedings under the Income Tax Act. Though this judgment is rendered with respect to compliance of RBI Directions on prudential norms regarding presentation of nonperforming assets, the ratio of this decision has a bearing on the instant case on hand. We have also perused the case Pearl Agencies v. Dy. CIT Delhi referred supra wherein it was held “As regards the question as to whether the debt in question really became bad in the year in which such a claim was made and the amount was debited in the profit and loss account with a corresponding credit to either the individual account of the debtor or to account like bad debt reserve account indicating the amount due by the particular debtor, it would be a sufficient compliance with the provisions of the statutory requirement for writing off as irrecoverable the concerned debt in the books of the assessee for the purposes of the Act. It is not essential that the debtor’s individual account be squared off by an appropriate credit entry. In the instant case the amount in question was debited in the profit and loss

ITA 842 & 799/JP/2013_ 9 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

account with a corresponding credit to bad debt reserve account. Hence, this condition also stood fulfilled in the case of the assessee. In view of the aforesaid facts and discussions, the assessee was entitled to grant of deduction of a sum of Rs.11,46,432 claimed as bad debt in the year under consideration.”

9.1 The Hon'ble Supreme Court in the case of T.R.F. Limited Vs CIT,

Ranchi in Civil Appeal No. 5293 of 2003 with 5294 of 2003 order dated

09/02/2010 has held as under:-

“This position in law is well settled. After 1st April, 1989, it is not necessary for the assessee to establish that the debt, in fact, has become irrecoverable. It is enough if the bad debt is written off as irrecoverable in the accounts of the assessee. However, in the present case, the Assessing Officer has not examined whether the debt has, in fact, been written off in accounts of the assessee. When bad debt occurs, the bad debt account is debited and the customer’s account is credited, thus, closing the account of the customer. In the case of

ITA 842 & 799/JP/2013_ 10 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

companies, the provision is deducted from Sundry Debtors. As stated above, the Assessing Officer has not examined whether, in fact, the bad debt or part thereof is written off in the accounts of the assessee. This exercise has not been undertaken by the Assessing Officer. Hence, the matter is remitted to the Assessing Officer for de novo consideration of the above-mentioned aspect only and that too only to the extent of the write off. Subject to above, the civil appeals filed by the assessee are disposed of with no order as to costs.”

9.2 The facts of Adea International Pvt. Ltd. Vs. ACIT are similar to the

facts of the assessee’s case and therefore, writing off bad debt in the

name of Nam Nam Dhaka is allowed and this ground of assessee’s appeal

stands allowed. Further whenever the bad debit written off is recovered

during subsequent year, it shall be treated income of that year.

disallowance of writing off loans and advances of Rs. 1,47,62,069/-. This

amount was written off by the BIFR order dated 08/05/2000.

A sum of Rs. 1,47,62,069/- was written off against loans and advances. The assessee was asked to produce details and its breakup and also to explain whether they are business loans/advances, how old are they, efforts made for recovery arid prove existence of party in form of full name, address etc.

ITA 842 & 799/JP/2013_ 11 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

The assessee filled reply stating therein that "Hon'ble Bench of BIFR scheme has sanctioned a rehabilitation scheme. As per this scheme the assets and liabilities would be limited to what was shown in the sanctioned scheme. In the scheme balance sheet for F.Y. 99-2000 has been re-casted by BIFR and only those items has been shown which are taken by the new management i.e. only those assets and liabilities have been shown which are recoverable and payable respectively by the new management and loans and advances which are not recoverable of Rs. 1,47,62,069/- has been written off at in the line of provision of the sanctioned scheme".

I have gone through the reply filed by the assessee and found the same not convincing. The assessee was asked to produce details of loans/advances, their breakup and the nature of the advance and efforts made for the recovery etc. But the assessee has filed a vague reply in place of giving the above details/correspondence regarding the advances written off. No reasons or correspondence with the defaulting parties have been furnished. It clearly shows that assessee has no reasonable cause for writing off the above loans and advances. In view of the same a sum of Rs. 1,47,62,069/- is disallowed.

was sanctioned for rehabilitation of the scheme. As per scheme, assets

and liabilities would be limited to what was shown in the sanctioned

scheme. In view of this scheme, the balance sheet for financial year 1999-

2000 was recasted. Only those items were shown in recasted balance

sheet, which were taken by the new management. Only those assets and

liabilities were shown, which were recoverable and payable respectively by

the new management and loans and advances which are not recoverable

ITA 842 & 799/JP/2013_ 12 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

were written off in the line of the sanctioned scheme. Considering these

facts, we find merit in the pleadings of the ld AR and therefore, we allow

this ground of appeal. This issue is also covered by the decision of the

Hon’ble Apex Court in the case of T.R.F. Limited Vs. CIT, Ranchi (supra).

fixed assets of Rs. 13,67,295/-. These assets were found missing during

the course of taking over of the operation of the company by the new

management and the company has written off these assets.

13.1 The ld. CIT(A) has dealt the issue by holding as under:

The assessee was asked to give detailed breakup of fixed assets of Rs. 13,67,295/- written off. It was asked to inform if any assets were lost. If there was any theft whether any First Information Report (FIR) was lodged regarding this by the company and whether insurance was claimed for the loss. The assessee filed a reply stating therein that above company was closed from 3rd June, 98 to 19th June, 2000 and an insurance policy expired and could not be renewed due to closure of the company. No FIR was filed by the new management, it was not ascertainable at the time of taking the possession by the new management what assets were missing during the closure period of the company.

When the books of accounts of the company were finalized then some assets were not found in the factory either they have been losses, vanished/stolen. The following fixed assets were written off :- Furniture and fixtures Rs. 914065/- Light vehicle Rs. 453229/-

ITA 842 & 799/JP/2013_ 13 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

Total Rs. 1367294/-''

The reply submitted by the assessee is baseless, The company has not filed any FIR of the fixed assets which were either stolen/lost. In absence of the FIR it cannot be ascertained whether these fixed assets were stolen or not. The assessee has also not claimed from the insurance company. All these facts clearly shows that no fixed assets were either stolen/lost. In view of above the claim of the assessee for write off of above fixed assets is disallowed.

The assessee did not furnish any details of the extraordinary losses except a summary in reply dated 27.02.2003. The figures of the same are not tallying with amount shown in the P & L account. Due to non-availability of details the claim of the assessee is not acceptable and Rs. 1,20,80,155/- is disallowed. Since, this sum includes the above discussed amounts written off regarding fixed assets, sundry debtors, loans and advances etc. therefore, no separate additions are being made on their account.

missing and the same were written off in the books of account. In our

considered view, this was not the proper way to deal with these missing

assets as these assets were already forming part of the block assets.

There was no need to writing off the same in the books of account as

these were merged in block of assets and depreciation was allowed. Since

no details are filed, hence, we find no merit in the ground. Therefore, we

confirm the order of the ld. CIT(A) on this issue and dismiss this ground of

appeal of the assessee.

ITA 842 & 799/JP/2013_ 14 Rajasthan Explosives & Chemicals Ltd. Vs JCIT The 4th ground of the appeal is against confirming the disallowance 15.

of interest amount of Rs. 35,00,000/-. This interest forms part of total

interest of Rs. 65,00,000/- which has been provided, as per the direction

given by the BIFR in scheme sanctioned on dated 08/5/2000.

15.1 The ld. CIT(A) has dealt the issue by holding as under:

An amount of Rs. 95,41,977/- has been debited to P&L account as payment of interest to financial institutions and banks on borrowed money. The assessee was asked to furnish details with name, address, amount and why should it not be disallowed U/s 43B as it is payment of interest to financial agencies eg. ICICI, IDBI, LIC, SBI etc.. Out of this a sum of Rs. 3041977/- has already been added back by assessee in computation of income. As regards the interest of Rs. 65,00,000/- being interest on cash credit limit of Rs. 2 crores as claimed by the assessee as deductable expenditure in P&L account, the assessee was asked to explain the same. The assessee replied that the interest payable on working capital to SBBJ would not be covered U/s 43B. Besides this the assessee has not submitted any details and basis of calculation regarding the amount of Rs. 65 lacs. The assessee’s contention cannot be accepted because as per balance sheet credit balance in cash credit limit was Rs. 2 crores and as per prevailing average bank lending rate @ 15% per annum the interest payable by the assessee comes to Rs. 30,00,000/-. The difference of Rs. 35,00,000/- is thus, disallowed and added to the assessee’s income.”

we find that the Assessing Officer has computed hypothetical interest by

adopting 15% rate of interest on an amount of Rs. 2 crores. Factually, the

actual interest paid on the working capital loan from bank are completely

ITA 842 & 799/JP/2013_ 15 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

different from what the Assessing Officer has assumed. The assessee

company was having working capital of Rs. 5,25,59,463/- as an opening

balance and there was closing balance of Rs. 5,17,52,067/-. Thus the

actual bank limit remained around Rs. 5.25 crores during the year. The

interest of Rs. 65.00 lacs has been on the amount of around 5.25 crores

and not on Rs. 2.00 crores as assumed by the Assessing Officer. The

assessee submitted the details of O.D. account for the relevant period

from 01/4/1999 to 31/3/2000. The loan as on 31/3/2000 from the bank

was Rs. 2.00 crores as cash credit, export bills and packing credit Rs.

79.52 lacs and working capital term loan Rs. 2.38 crores. The part of the

working capital loans were converted during the year as working capital

term loan as per the scheme of the BIFR. Thus the total loan outstanding

of bank towards the working capital was Rs. 5,17,52,067, which is

verifiable from the balance sheet as on 31/3/2000. Further the assessee

company has charged interest of Rs. 6.50 lacs only in the P&L account,

which is a net effect of 90% of the interest payable. As per the scheme of

the BIFR, the balance amount has been credited to extra ordinary income.

Keeping in view of these facts and circumstances, we find no merit in this

addition and direct to delete the same. Accordingly the appeal of the

assessee is partly allowed. In the result, the revenue’s appeal is dismissed

and the appeal of the assessee is partly allowed.

ITA 842 & 799/JP/2013_ 16 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

additional grounds, which is read as under:-

“6. That the A.O./CIT(A) has erred in law and on facts, in nor reducing the assessable income by Rs. 6,04,98,043/-, which is included in the Profit and Loss account as extraordinary income and the same is not taxable in view of the scheme sanctioned by the BIFR. The A.O. is bound to assess the correct income under the law.

The ld AR pleaded that the relevant facts with regard to these grounds are

on record and no new facts is required to be investigated and these

grounds go to the root of the matter, therefore, in view of the decision of

the Hon'ble Supreme Court in the case of NTPC 229 ITR 383 (SC) be

admitted. Since this is the first time raised before the ITAT and the

assessee’s claim need to be verified at the level of the Assessing Officer,

therefore, it was also pleaded that the issue raised in these grounds may

be restored to the file of the Assessing Officer.

raised by the assessee. The Hon'ble Supreme Court in the case of National

Thermal Power Co. Ltd. Vs. CIT (1998) 229 ITR 383 (SC) has held as

under:-

ITA 842 & 799/JP/2013_ 17 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

Under section 254 of the Income-tax Act, 1961, the Appellate Tribunal may, after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it thinks fit. The power of the Tribunal in dealing with appeals is thus expressed in the widest possible terms. The purpose of the assessment proceedings before the taxing authorities is to assess correctly the tax liability of an assessee in accordance with law. If, for example, as a result of a judicial decision given while the appeal is pending before the Tribunal, it is found that a non-taxable item is taxed or a permissible deduction is denied, there is no reason why the assessee should be prevented from raising that question before the Tribunal for the first time, so long as the relevant facts are on record in respect of the item. There is no reason to restrict the power of the Tribunal under section 254 only to decide the grounds which arise from the order of the Commissioner of Income-tax (Appeals). Both the assessee as well as the Department have a right to file an appeal/cross-objections before the Tribunal. The Tribunal should not be prevented from considering questions of law arising in assessment proceedings, although not raised earlier. The view that the Tribunal is confined only to issues arising out of the appeal before the Commissioner (Appeals) is too narrow a view to take of the powers of the Tribunal.

Undoubtedly, the Tribunal has the discretion to allow or not to allow a new ground to be raised. But where the Tribunal is only required to consider the question of law arising from facts which are on record in the assessment proceedings, there is no reason why such a question should not be allowed to be raised when it is necessary to consider that question in order to correctly assess the tax liability of an assessee.

During the assessment year 1978-79, the assessee had deposited its funds which were not immediately required on short-term deposits with banks. Interest received on such deposits during the previous year relevant to the assessment year 1978-79 amounted to Rs. 22,84,994. This was offered by the assessee for assessment and the assessment was completed on that basis. Before the Commissioner of Income-tax (Appeals), a number of grounds were taken by the assessee challenging the assessment. However, the inclusion of this amount of Rs. 22,84,994 was neither challenged by the assessee nor considered by the Commissioner of Income-tax (Appeals). From the order of the Commissioner of Income-tax

ITA 842 & 799/JP/2013_ 18 Rajasthan Explosives & Chemicals Ltd. Vs JCIT

(Appeals), the assessee filed an appeal before the Tribunal. The inclusion of the said amount of Rs. 22,84,994 was not objected to even in the grounds of appeal as originally filed before the Tribunal. However, by a forwarding letter dated July 16, 1983, the following additional grounds were sought to be raised by the assessee: (1) that the sum of Rs. 22,84,994 deducted from "Statement of expenditure during construction" could not be included in the total income; (2) that on admission (erroneous), no income (the sum of Rs. 22,84,994) could be included in the total income; and (3) that the authorities below had erred and failed in their duty in not adjudicating the facts and evidence on record and mechanically included Rs. 22,84,994 in the total income. The assessee contended that it learnt that the interest earned before the setting up of business was not taxable as income and it went to reduce the capital cost of the plant and hence included the above three grounds in its grounds of appeal. However, the Tribunal declined to entertain the three additional grounds. The Tribunal directly referred to the Supreme Court the question whether where, on the facts found by the income-tax authorities, a question of law arose (although not raised before the authorities) which bore on the tax liability of the assessee the Tribunal had jurisdiction to examine the same:

Held, that the Tribunal had jurisdiction to examine a question of law which arose from the facts as found by the income-tax authorities and having a bearing on the tax liability of the assessee.”

In view of the binding precedent of the Hon'ble Supreme Court in the

decision of (supra), the matter raised in the additional grounds is

remanded back to the file of the Assessing Officer to be decided on merit.

assessee is allowed for statistical purposes only.

ITA 842 & 799/JP/2013_ 19 Rajasthan Explosives & Chemicals Ltd. Vs JCIT 20. In the result, the revenue’s appeal is dismissed and the appeal of

the assessee is partly allowed.

Order pronounced in the open court on 11/04/2017.

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