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Income Tax Appellate Tribunal, MUMBAI BENCH “B”, MUMBAI
Before: SHRI G.S. PANNU & SHRI SANDEEP GOSAIN
PER G.S. PANNU, AM :
The captioned appeal filed by the assessee pertaining to Assessment Year 2011-12 is directed against an order passed by Director of Income-Tax (Exemptions) dated 22.02.2011 denying registration u/s 12A of the Income Tax Act, 1961 (in short ‘the Act’).
In its appeal, assessee has raised the following Grounds of appeal :-
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“1. On the facts and circumstances of the case, the appellant prays to condone the delay in filing of an appeal.
On the facts and circumstances of the case, the appellant was prevented by reasonable cause from filing appeal in time and prays to condone the delay in filing of appeal.
The learned DIT (Exemption) erred in not granting the registration of the Trust u/s.12A / 12AA of the IT Act on the ground that the main object of the Trust is not for general public but for the sole benefit of the employees of the bank and hence the trust cannot be termed as Charitable Trust within the meaning of the provisions of Sec. 2(15) of the act.
The DIT (E) failed to appreciate:
a. that the members of the scheme are retired employees of the Bank across the country who have paid membership fee which is equivalent to their last Basic Pay drawn, are general public. The average membership fee is Rs.24,500.00 (approx.) as against members are reimbursed Rs.2000 every year towards domiciliary medical expenses and also upto Rs.100000 towards hospitalization expenses/insurance premium during the lifetime of the member and spouse. b. that the benefit to the members of the scheme is not extended to the existing employees of the bank. c. that the retired employees are not the employees of the bank and bank is not bound to provide any benefit or welfare of the employees who have already retired from the service-and hence above benefits are extended to them under the scheme. d. that the DIT(E) is not required to go in to the future activities of the Trust. e. that the trust is genuine and is solely providing the medical assistance i.e. for charitable purpose and by no stretch of imagination it can be stated to be for non charitable purpose.
The DIT(E) erred in not granting the regular registration u/s.12A / 12AA as a Charitable Trust though the trust is not for the employees of the bank but those who have retired from the bank and have no connection with bank. The trust is for the charitable object.”
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As a perusal of the Grounds of appeal reveal, the sum and substance of the grievance of the assessee is the denial of registration by the Director of Income-Tax (Exemptions) (in short ‘the Director’) u/s 12A of the Act. Before proceeding with the merit of the controversy, it was noted that there was a delay in filing of appeal by 927 days. The appellant has made an application for condonation of delay dated 27.11.2013 wherein it is canvassed that the delay be condoned. The plea of the assessee is that the delay is not deliberate, but due to administrative exigencies. In support of the application, two Affidavits have also been submitted wherein detailed averments have been made enumerating the reasons for the delay. Firstly, an Affidavit dated 22.11.2013 has been filed by one, Shri Uday Ramchandra Dravid, Managing Trustee of the assessee-trust, the relevant contents of which read as under :-
“3. I would like to submit as under:-
a) The Bank of India has formed a Trust on 30/01/2008 named as “Bank of India Retired Employees' Medical Assistance Trust under which the Bank has formulated a Scheme which is extended to all the members of the scheme who are retired employees of the Bank for providing financial assistance to them to meet the medical expenses incurred by such members and his/her dependant spouse.
b) The Scheme framed as above is administered by the Trust and accordingly the application was filed in form no.10A on 24/08/2010 for registration under Section 12(A) of the Income Tax Act, 1961.
c) The Hon'ble Income Tax Officer (HQ) (Exemption) for DIT (E) Mumbai has rejected application for registration under the Charitable Trust Act vide order No.DIT(E)/ u/s. 12A/43878/10-11 dated 22/02/2011. On receipt of the order from the authorities concerned, the necessary
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consultation/advice was being sought from the Bank's Chartered Accountant for filing an appeal against the aforesaid order.
d) Presently the Trust is managed by the Bank of India, Terminal Benefits Division at Head Office and the entire management is being done by the Bank employees on honorary basis. Even the trustees of the Trust are not being paid any remuneration for the same.
e) The bank of India Retired Employees' Medical Assistance Scheme managed by the Trustees covers retired employees of the Bank who have become member of the scheme and his/her spouse and on the death of member the spouse will continue to be covered under the scheme for reimbursement of medical expenses. Under this scheme the Bank is presently having 10,214 members and such members/ their spouse are extended the medical assistance including hospitalization expenses as and when necessary. This number is increasing periodically. The Corpus of the trust is raised out of one time lump sum contribution equal to 100% of the Basic Pay last drawn received from a retired employee/ spouse of the deceased retired employee and contribution received from Bank's Central Welfare Committee. The trust is earning interest on the fixed deposits. The trust applies its funds entirely towards reimbursement of Insurance Premium, Domiciliary Medical Expenses and Hospitalization Expenses to the members of the scheme.
f) While the process of filing the appeal was under examination, officer looking after it and monitoring the fund got transferred on account of promotion. Some of the officers have also been retired on superannuation. Consequently from the March 2011 till November 2013 the matter regarding filling of the appeal could not be finally discussed and hence there is genuine and bonafide delay on the part of the trust for preferring such appeal before the Appellate Authority against order of the Hon'ble DIT(E).
g) We may submit that the aforesaid Trust are being managed by the department officials along with other related assigned duties to them
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and hence there is no full-fledged officer/ employee to look after the Trust Management and its administration.
h) As a result of the above, there is a delay of more than 2 years 6 months in filing of the appeal however the said delay is not deliberate but due to administrative exigencies as a result of which if the delay is not condoned there would be irreparable loss to Trust whereas if the delay is condoned no loss is to be likely to the Government.
i) We may submit that the aforesaid medical assistance scheme is being a social measure and beneficiaries of the said scheme are spread over across the country who were working in more than 4400 branches and had retired on account of superannuation. Thus this being a social welfare in tune with government guidelines, we consider that the delay on account of filing of the appeal may be necessarily condoned so that the appeal can be heard on its merit.
In view of the above facts, no instruction could be given to file an appeal against the order of DIT(E) and hence the filing of an appeal was delayed by 2 years and 6 months.
There was no malafide intention to delay the matter.”
Thereafter, another Affidavit dated 05.05.2017 has been filed by one, Shri B.M. Wasaikar, Trustee of the assessee-trust, whose relevant content read as under :-
“I B.M. Wasaikar, Indian Resident and a trustee of Bank of India Retired Employees Medical Assistant Trust, solemnly declared and affirm as under:
1) I, being a Senior Officer of Bank of India, I am one of the trustee of Bank of India Retired Employees' Medical Assistant Trust.
2) I, being trustee, am aware of the facts of the trust.
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3) The trust had made an application before Director of Income Tax (Exemption) Mumbai for Registration of Trust under section 12A of the Income Tax Act, 1961 on 24th August, 2010. However the said application was rejected by Director of Income Tax (Exemption) as per order passed u/s 12AA(1)(b)(ii) r.w.s. 12A of the Income Tax Act, on 22nd February, 2011. The order was received by trust on 15th March. 2011.
4) The said order was received by Shri. Sanjay P Walimbe, Officer of Bank of India, who was entrusted the work of looking after Registration of Trust, settlement of claims, enrollment of new members of retirement etc. He, being an employee, of Bank was also looking after Pension payments and work of Bank. The person who looks after the work of trust are not paid salary and are doing honorary work.
5) Month of March is always very busy month since all claims related papers are required to be sorted before the year end i.e. March. Hence Shri. Sanjay P Walimbe could not look into matter relating to order received from Director of Income Tax (Exemption).
6) Mr. Sanjay P. Walimbe was then transferred to Kolhapur Zone on promotion in April, 2011 and no new dedicated officer was appointed to look after affairs of the trust. He, therefore, could not give charge to next person.
7) Some where in October, 2011, Mrs. Manisha Bhide, an officer was allocated to look after trust affairs over and above her usual office work.
8) Since nobody handed over charge to her, she was not aware of receipt of rejection order received from Director of Income Tax (Exemption).
9) Somewhere in first week of November, 2013, the trust received a notice dated 31st October, 2013 from Assessing Officer on taking up scrutiny assessment of A.Y. 2011-12. In the said notice, the A O asked
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to furnish Certificate of Registration under section 12A (Query No. 4). Immediately Mrs. Manisha Bhide searched for the said document but could not found. She then talked to Mr. Sanjay Walimbe and realized that order rejecting the application for registration of trust u/s 12A has been received and appeal is required to be filed.
10) She immediately drawn the attention of trustees and tax consultant to do the needful.
11) Accordingly an appeal against the rejection order was filed on 26th November, 2013
12) Hence there was delay in filing of an appeal by 2 years and 8 months.
13) I, on behalf of the trust, plead that the delay in filing of appeal may be condoned.”
At the time of hearing, the learned representative for the assessee pointed out that the delay in filing of the appeal has taken place in two stages inasmuch as the appeal was actually filed on 26.11.2013 whereas the Affidavit of the Managing Trustee explains the delay of two years and six months only. As there was a further delay of two months in filing of appeal after the preparation of the appeal and the earlier Affidavit, another Affidavit was filed by another Trustee, Shri B.M. Wasaikar explaining further delay of two months. In sum and substance, both the Affidavits point out similar reason for the delay. It is canvassed by the learned representative that the Trust is set-up in terms of a Scheme formulated by Bank of India whereby financial assistance to meet the medical expenses incurred by its Members and their dependent spouse was sought to be provided. It is pointed out that all the Members of the Scheme are retired employees of the Bank. It is also pointed out that the Trust is managed by Bank of India,
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Terminal Benefits Division of its Head Office and the entire management is looked after by the Bank employees on honorary basis. Even the Trustees do not get any remuneration for looking after the affairs of the Trust. It is pointed out that the corpus of the Trust is raised out of a one-time lump sum contribution equal to 100% of the basic pay last drawn received from a retired employee and the contribution received from the Bank’s Central Welfare Committee. The earning of the Trust is primarily by way of interest on fixed deposits which is applied entirely towards reimbursement of insurance premium, domiciliary expenses and hospitalisation expenses of the Members of the Scheme. It was pointed out that after the receipt of the order of the Director of Income-tax (Exemptions), the process of filing of appeal was under consideration and the officer looking after it got transferred on promotion and some of the officers retired on superannuation. Therefore, starting from March, 2011 when the impugned order was received and till November, 2013, the matter relating to filing of appeal could not attain finality. In this context, the learned representative not only referred to the averments made in the Affidavits, but also to the Paper Book wherein is placed a copy of inter-office memorandum of the Bank depicting the transfer of the concerned employee who was looking after the affairs of the Trust in the month of April, 2011. It has also been explained that the factum of non-filing of the appeal against the denial of registration came to be highlighted in October, 2013 when the then honorary office bearers were appearing before the Assessing Officer in connection with the assessment proceedings for Assessment Year 2011-12. When the Assessing Officer asked for a copy of the Certificate of Registration u/s 12A of the Act, it came to light that the impugned order of the Director rejecting the application for registration has not been appealed against.
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Thereafter, assessee took steps and filed the appeal. The learned representative vehemently pointed out that the assessee-trust is comprised of former employees of Bank of India, which is a public sector bank, and that it is for providing financial assistance to meet the medical expenses of the retired employees and their dependent spouse. The learned representative pointed out that though the delay was long, yet that cannot be a reason to reject the plea for condonation of delay and, for that matter, relied on the following judgements :-
i) N. Balakrishnan vs M. Krishnamurthy, 7 SCC 123; ii) Baburao Deorao Wankhede vs Sewa Sahakari Sanstha & Anr., W.P No. 1974 of 1979 dated 02.08.1988; and, iii) Sonerao Sadashivrao Patil & Anr. vs Godawaribai w/o Laxmansigh Gahirewar & Ors, Civil Revision Application No. 904 of 1990 dated 23.03.1999.
On the other hand, the ld. DR appearing for the Revenue opposed the plea for condonation of delay by pointing out that assessee has not denied the awareness about the order of the Director rejecting the registration and, therefore, it is a case where there is negligence on the part of the assessee in not preferring the appeal in time before the Tribunal.
We have carefully considered the rival submissions. The reasons for the delay have been succinctly brought out in the Affidavits filed, whose relevant portions have already been extracted by us in the earlier part of this order. It is explained that the affairs of the Trust are being looked after by the employees of Bank of India on an honorary basis. It is also canvassed
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that the Trustees of the Trust are also drawn from the employees of Bank of India who are also not paid any remuneration. Ostensibly, the Bank formulated a Scheme for its retired employees for providing financial assistance to meet expenses incurred by such retired employees and/or their dependent spouse. The entire circumstances show that the objects are to provide financial assistance to meet the medical expenses of the former employees of the Bank who become Members of the instant Trust. It is also emerging from record, and there is no controversion to such averments, that the Trust is being manned by the employees of Bank of India on a honorary basis. It is a well-settled proposition that while evaluating the reasons for delay in filing of an appeal, a liberal and practical approach has to be adopted by the authorities exercising judicial/quasi-judicial functions. In the case before us, there is no material to doubt the bona fide of the reasons, though there is lapse on the part of the assessee in filing the appeal promptly. The length of the delay is not paramount and rather, the quality of the explanation is paramount to decide as to whether or not the delay deserves to be condoned. The Hon'ble Supreme Court in the case of N. Balakrishnan vs M. Krishnamurthy (supra) observed that “length of delay is no matter, acceptability of the explanation is the only criteria”. In fact, in the case of Baburao Deorao Wankhede vs Sewa Sahakari Sanstha & Anr. (supra) the Hon'ble Bombay High Court was dealing with delay in filing of Writ Petition by almost 10 years. Though the Hon'ble High Court observed that there was an inordinate delay, but considering the interests of justice the Hon'ble High Court condoned the delay. In coming to such a conclusion, the Hon'ble High Court referred to and relied upon the judgment of the Hon'ble Supreme Court in the case of Collector, Land Acquisition vs Mst. Katiji & Ors., 167 ITR 471 (SC). Considering the reasons averred, whose bona fide are not
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in dispute, the delay in filing of the appeal deserves to be condoned. We hold so.
At the time of hearing, both the parties also made arguments with regard to the merit of the dispute. The grievance of the assessee is that the Director has unjustly denied registration u/s 12A of the Act. Notably, Sec. 12AA of the Act empowers the Director to grant registration after being satisfied about the objects of the Trust and the genuineness of its activities. In the present case, the primary object of the Trust is to administer financial assistance towards medical needs of the retired employees of Bank of India who are its Members and the dependent spouse of such retired employee- members in terms of the rules and regulations of the Scheme. It is also notable that the corpus of the Trust enures from one-time lump sum contribution equal to 100% of the basic pay last drawn received from the retired employees and the contribution received from Bank’s Central Welfare Committee. In sum and substance, the dominant object of the Trust is to provide assistance towards the medical needs of the retired employees of the Bank who are its Members in terms of the Scheme. At this stage, we may also observe that the expression “charitable purpose” has been defined in Sec. 2(15) of the Act to mean to include relief of poor, education, medical relief, etc. as well as advancement of any other objects of general public utility.
The Director has denied exemption solely on the ground that assessee-trust’s objects are not for the benefit of the general public, but only for its specific Members/employees of Bank of India. In our considered
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opinion, the aforesaid proposition sought to be raised by the Director is quite untenable and is directly contrary to the observations of the Hon'ble Supreme Court in the case of Ahmedabad Rana Caste Association vs CIT, 82 ITR 704 (SC). At the time of hearing, the learned representative for the assessee relied upon the aforesaid decision to canvass that an object beneficial to a section of the public would fall within the purview of ‘charitable purpose’ and it is not necessary that the object should be to benefit the whole of mankind. Furthermore, the Hon'ble Supreme Court in Ahmedabad Rana Caste Association (supra) has observed that “the object would remain charitable if the intention is to benefit a section of the public as distinguished from a specified individual”. To the similar effect is the judgment of the Hon'ble Andhra Pradesh High Court in the case of CIT vs Andhra Pradesh Police Welfare Society, 148 ITR 287 (AP) wherein the judgment of the Hon'ble Supreme Court in the case of Ahmedabad Rana Caste Association (supra) has been relied upon to uphold the grant of exemption u/s 11 of the Act to an entity which was constituted for the benefit of the members of police department and their families. Therefore, in our view, the objection raised by the Director is inconsistent with the legal position and thus deserves to be set-aside.
The Director relied upon the judgment of the Hon'ble Kerala High Court in the case of CIT vs Ernakilam District Cement Dealers Association, 253 ITR 198 (Ker) to canvass that in the absence of any intention to benefit the general public or any section of the general public, the exemption under Section 11/12 of the Act cannot be allowed. We have perused the decision of Hon'ble Kerala High Court. In the case before the Hon'ble Kerala High
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Court, the assessee was an association which was formed for the common benefit of its members who were traders in cement. The association had earned certain income by rendering clearing and handling services to its members and exemption u/s 11 of the Act was sought on such income. In this background, the Hon'ble High Court noted that there was no charitable purpose involved in the activities of the association and that the object was merely to benefit the trader members of the association. The Hon'ble High Court specifically noted that there was no provision of any relief to the poor or for education or for medical relief and the advancement of any other object of general public utility as contemplated by Sec. 2(15) of the Act. The aforesaid features of the case before the Hon'ble Kerala High Court stand apart from the facts in the instant case before us. Pertinently, the case before us is of a public sector bank and for providing medical relief to its retired employees who opt to be the Members of the assessee-trust. Furthermore, in the case before the Hon'ble Kerala High Court, the income in question was obtained by rendering clearing and handling services to the cement trader members whereas the instant is not a case where exemption is being sought on income earned from rendering of services to its Members. Be that as it may, there is a qualitative difference in facts that were before the Hon'ble High Court and the facts before us and, therefore, in our view, the judgment of the Hon'ble Kerala High Court in the case of Ernakilam District Cement Dealers Association (supra) has been wrongly invoked by the Director in the instant case.
Secondly, the Director has also relied upon the judgment of the Hon'ble Bombay High Court in the case of Zenith Tin Works Charitable Trust
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vs CIT, 102 ITR 119 (Bom.) to say that any object of a Trust to provide for welfare of the employees of the Trust or institution cannot be regarded as a charitable purpose. In this context, we have carefully perused the judgement of the Hon'ble Bombay High Court in the case of Zenith Tin Works Charitable Trust (supra). The relevant facts before the Hon'ble High Court were as follows. It was noticed by the Hon'ble High Court that the assessee- trust before it had multiple objects which were charitable, but one object was to provide for the welfare of the employees of the Trust or any institution conducted by the Trust. According to the Hon'ble High Court, the aforesaid object could not be regarded as an object of public charitable nature, though the other objects were of public nature. In coming to such a decision, the Hon'ble High Court also noted a specific clause in the Trust Deed which authorised the Trustee to utilise the corpus of the Trust property or any part thereof for any one or more objects of the Trust and in such proportion as they may in their absolute discretion think fit. The presence of the aforesaid clause in the Trust Deed was interpreted to mean that the Trustees could, if they thought it fit in their absolute discretion, spend not merely the entire income, but even the entire corpus of the Trust over any particular object of the Trust including the object of welfare of its employees, which could not be said to be an object of public nature. In our considered opinion, the fact-situation in the instant case stands on a different footing. Pertinently, the matter before the Hon'ble High Court in the case of Zenith Tin Works Charitable Trust (supra) was of a private enterprise inasmuch as the Settlors therein were interested in a private enterprise called Zenith Tin Works Pvt. Ltd. On the contrary, the Trust before us is in terms of a Scheme formulated by a public sector bank for medical assistance of its retired employees and their dependent spouse.
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Ostensibly, before the Hon'ble High Court it was a case of a private employment while the case before us involves a public employment inasmuch as the Members of the Trust are retired employees of a public sector government-owned bank. The distinction between the two has been aptly noted by the Hon'ble Andhra Pradesh High Court in the case of Andhra Pradesh Police Welfare Society (supra). In the case before the Hon'ble Andhra Pradesh High Court the issue related to a Trust which was established for the benefit of Members of the police and their families. In opposing the entitlement to exemption u/s 11 of the Act vis-a-vis the expression “charitable purpose” u/s 2(15) of the Act, the Revenue canvassed before the Hon'ble High Court that it is a case of a personal nexus between the employer and the employees. In negating this argument, the Hon'ble High Court drew a distinction between cases of public employment wherein it was held that the nexus is impersonal in nature vis-a-vis a private employment, which was of a personal nature. The following discussion in the order of the Hon'ble High Court is worthy of notice.
“..........In fact, the contention which was advanced by the learned standing counsel for Income-tax is mostly with reference to the nature and character of the beneficiaries of the trust, viz., the member of the assessee- society, who are the employees of a section of the Government Department. Therefore, the main thrust was, deriving inspiration from the decision in Oppenheim v. Tobacco Securities Trust Co. Ltd., [1951] AC 297; [1951] 1 All ER 31 (HL), that there was no nexus between the propositus and the employees and so it cannot be said to constitute either public or a section of the public. If that be so, the benefit contemplated under the Act cannot be extended. Here we propose to confine ourselves to the question as to whether the members of the assessee-society, who doubtless are the employees of the police department under aegis of the State Government, are entitled to the benefit. So, the immediate question is whether the nexus between the Government, which is said to be the employer and the
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police personnel, the members of the society, is of personal or impersonal nature. That poses, indeed, an interesting question, which the learned counsel for the assessee, Sri Y. V. Anjaneyulu, very rightly submitted, i.e., there cannot be any analogy between public employment and private employment. Surely, in the case of private employment, such nexus being personal, is conspicuous. But, in so far as public employment is concerned and in particular the Governments formed by, for and of the people is the employer, even if it is to be taken in a restrictive sense, and the employer is the representative of the public or the people. In the ultimate analysis, it is the public that is the employer; qui facit per alium facit per se and so, to the service rendered by the employees in the public employment, the beneficiaries are the public. Testing, therefore, from that angle, the nexus which exists in case or private employment and which is of personal nature, cannot be said to be so in case of public employment. If that be so, in our judgment, the nexus in the case of public employment is its impersonal nature.”
Therefore, following the aforesaid decision of the Hon'ble Andhra Pradesh High Court in the case of Andhra Pradesh Police Welfare Society (supra), the plea of the assessee for registration u/s 12A of the Act has to be upheld and on account of distinction in facts, in our view, the Director erred in relying on the decision of the Hon'ble Bombay High Court in the case of Zenith Tin Works Charitable Trust (supra) to deny registration u/s 12A of the Act to the assessee-trust.
A perusal of the impugned order reveals that reference has also been made to the judgment of the Hon'ble Madras High Court in the case of Sakthi Charities vs CIT, 149 ITR 624 (Mad) which, in our view, is also inapplicable as it was a case of a private employment.
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Thus, in conclusion, we hereby set-aside the order of the Director and hold that the assessee is eligible for registration u/s 12A of the Act. Accordingly, it is directed that registration u/s 12A of the Act be granted to be assessee.
In the result, appeal of the assessee is allowed.
Order pronounced in the open court on 3rd October, 2018.
Sd/- Sd/- (SANDEEP GOSAIN) (G.S. PANNU) JUDICIAL MEMBER ACCOUNTANT MEMBER
Mumbai, Date : 3rd October, 2018
Copy to :
1) The Appellant 2) The Respondent 3) The CIT(A) concerned 4) The CIT concerned 5) The D.R, “B” Bench, Mumbai 6) Guard file
By Order
Dy./Asstt. Registrar I.T.A.T, Mumbai