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Income Tax Appellate Tribunal, “E”
Before: SHRI R. C. SHARMA, AM & SHRI AMARJIT SINGH, JM
आदेश / O R D E R PER AMARJIT SINGH, JM: The Revenue as well as Assessee have filed the above mentioned appeals as well as cross objection against the different order passed by the Commissioner of Income Tax (Appeals)-18, Mumbai [hereinafter referred to as the “CIT(A)”] relevant to the A.Y.2009-10 & 2010-11. ITA. NO.6153/M/2014:- 2. The revenue has filed the present appeal against the order dated 18.07.2014 passed by the Commissioner of Income Tax (Appeals)-18, Mumbai [hereinafter referred to as the “CIT(A)”] relevant to the A.Y.2009- 10.
The Revenue has raised the following grounds: - (1). ''Whether on the facts and m the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the disallowance made u/s 24 towards interest of Rs,33,27,470/- paid in respect of loan taken from M/s, India Bulls Financial Services Ltd.?" 11. "Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A} erred in holding that the loans received from M/s India Bulls Financial Services Ltd had been utilized for reimbursement of loans already taken for purchase of property at Pune on which the assessee had shown rental income) without appreciating that neither a fund flow statement nor any specific evidence was furnished by the assessee- company to substantiate direct utilization of loans taken from M/s India Bulls Financial Services Ltd towards repayment of earlier loans?" III. "Whether on the facts and in the circumstances of the case and in law, the Ld.CIT[A) erred in holding that loans received in AY 2GG8-Q9 from M/s India. Bulls Financial
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Services Ltd., had been utilized for reimbursement of loans already taken for purchase of property at Pune without appreciating that unsecured loans to the tune of RS, 4,42 crores received from other companies were used in that year for purchase of shares and even in respect of squared off loans totaling to Rs.1.09 crores taken from directors/share-holders, no corroborative evidence was filed by the asses see company to substantiate that these funds had been indeed utilized for repayment of earlier loans?" iv. "The appellant prays that the order of the C3T (A) on the above grounds be set aside and that of the A.O. be restored." v. "The appellant craves leave to amend or alter any grounds or add a new ground which may be necessary.” We have heard the arguments advanced by the Ld. 4. Representative of the parties and perused the record. In the present case the revenue has challenged the deletion of addition made u/s 24 of the Act towards interest of Rs.33,27,470/- paid in respect of loan taken from M/s. India Bulls Financial Services Ltd. At the very outset, the Ld. Representative of the assessee has argued that in the present case, we found that tax effect in the appeal so filed by the Revenue is below Rs.20 lakhs. In order to cut down on frivolous litigation and taxpayer’s grievance, the CBDT, which formulates policies for the Income Tax Department, has issued recent instruction No.3/2018 dated 11/07/2018 revising the monetary threshold fixing the tax effect limit of Rs.20 lacs for the revenue to file appeal before the ITAT and
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since in this appeal, the tax effect is below Rs.20 lakhs, the appeal filed by the revenue is not maintainable and liable to be dismissed in limine.
The CBDT in its Circular No.3/2018 dated 11th July 2018 have 3. revised the monetary limit to Rs.20 Lakhs to file the appeal before the Tribunal by the Revenue. On scrutiny of appeal filed by the revenue, it is found that the total tax demand is below the prescribed limit of Rs.20 lakhs. The CBDT also clarifies that this instruction will apply retrospectively to pending appeals and appeals to be filed henceforth in High Courts/Tribunal. The Income Tax Act was amended and Section 268A has been introduced on the Statute book with retrospective effect. Section 268A carves out an exception for filing of appeals and References under section 260A of the Act. The legislature has prescribed that the CBDT is empowered to issue circulars and instructions from time to time, with regard to filing of appeals depending on the tax effect involved. The relevant circular issued by CBDT reads as under:
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“Reference is invited to Board’s Circular No. 21 of 2015 dated 10.12.2015 wherein monetary limits and other conditions for filing departmental appeals (in Income-tax matters) before Income Tax Appellate Tribunal, High Courts and SLPs/ appeals before Supreme Court were specified. 2. In supersession of the above Circular, it has been decided by the Board that departmental appeals may be filed on merits before Income Tax Appellate Tribunal and High Courts and SLPs/ appeals before Supreme Court keeping in view the monetary limits and conditions specified below. 3. Henceforth, appeals/ SLHs shall not be filed in cases where the tax effect does not exceed the monetary limits given hereunder; S. No. Appeals/ SLPs in Monetary Limit (Rs Income-tax matters
20,00,000 1. Before Appellate Tribunal
Before High Court 50,00,000 1,00,00,000 3. Before Supreme Court
It is clarified that an appeal should not be filed merely because the tax effect in a case exceeds the monetary limits prescribed above. Filing of appeal in such cases is to be decided on merits of the case.
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For this purpose, 'tax effect' means the difference between the tax on the total income assessed and the tax that would have been chargeable had such total income been reduced by the amount of income in respect of the issues against which appeal is intended to be filed (hereinafter referred to as 'disputed issues). Further, “tax effect” shall be tax including applicable surcharge and cess. However, the tax will not include any interest thereon, except where chargeability of interest itself is in dispute. In case the chargeability of interest is the issue under dispute, the amount of interest shall be the tax effect. In cases where returned loss is reduced or assessed as income, the tax effect would include notional tax on disputed additions. In case of penalty orders, the tax effect will mean quantum of penalty deleted or reduced in the order to be appealed against. 5. The Assessing Officer shall calculate the tax effect separately for every assessment year in respect of the disputed issues in the case of every assessee. If, in the case of an assessee, the disputed issues arise in more than one assessment year, appeal can be filed in respect of such assessment year or years in which the tax effect in respect of the disputed issues exceeds the monetary limit specified in para 3. No appeal shall be filed in respect of an assessment year or years in which the tax effect is less than the monetary limit specified in para 3. In other words, henceforth, appeals can be filed only with reference 10 the tax effect in the relevant assessment year. Howeve,r in case of a composite order of any High Court or appellate authority, which involves more than one assessment year and common issues in more than one assessment year, appeals shall be filed in respect of all such assessment years even if the tax effect is less than the prescribed monetary limits in any of the year(s), if it is decided to file appeal in respect of the year(s) in which tax effect exceeds the monetary
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limit prescribed. In case where a composite order / judgement involves more than one assessee, each assessee shall be dealt with separately. 6. Further, where income under the provisions of section 115JB or section 115JC for the purposes of determination of 'tax effect', tax on the total income assessed shall be computed as per the following formula. (A - B) + (C — D) where, A - the total income assessed as per the provisions other than the provisions contained in section 115JB or section 115JC (herein called general provisions); B = the total income that would have been chargeable had the total income assessed as per the general provisions been reduced by the amount of the disputed issues under general provisions; C = the total income assessed as per the provisions contained in section 115J B or section 115JC; D = the total income that would have been chargeable had the total income assessed as per the provisions contained in section 115JB or section 115 JB was reduced by the amount of disputed issues under the said provisions: However, where the amount of disputed issues is considered both under the provisions contained in section 115JB or section 115JC and under general provisions, such amount shall not be reduced from total income assessed while determining the amount under item D.
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In a case where appeal before a Tribunal or a Court is not filed only on account of the tax effect being less than the monetary limit specified above, the Pr. Commissioner of Income-tax/ Commissioner of Income Tax shall specifically record that "even though the decision is not acceptable, appeal is not being filed only on the consideration that the tax effect is less than the monetary limit specified in this Circular". Further, in such cases, there will be no presumption that the Income-tax Department has acquiesced in the decision on the disputed issues. The Income-tax Department shall not be precluded from filing an appeal against the disputed issues in the case of the same assessee for any other assessment year, or in the case of any other assessee for the same or any other assessment year, if the tax effect exceeds the specified monetary limits. 8. In the past, a number of instances have come to the notice of the Board, whereby an assessee has claimed relief from the Tribunal or the Court only on the ground that the Department has implicitly accepted the decision of the Tribunal or Court in the case of the assessee for any other assessment year or in the case of any other assessee for the same or any other assessment year, by not tiling an appeal on the same disputed issues. The Departmental representatives/counsels must make every effort to bring to the notice of the Tribunal or the Court that the appeal in such cases was not filed or not admitted only for the reason of the tax effect being less than the specified monetary limit and, therefore, no inference should be drawn that the decisions rendered therein were acceptable to the Department. Accordingly, they should impress upon the Tribunal or the Court that such cases do not have any precedent value and also bring to the notice of the Tribunal/ Court the provisions of sub section
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(4) of section 268A of the Income-tax Act, 1961 which read as under *(•4) The Appellate Tribunal or Court, hearing such appeal or reference, shall have regard to the orders, instructions or directions issued under sub-section (1) and the circumstances under which such appeal or application for reference was filed or not filed in respect of any case." 9. As the evidence of not Cling appeal due to this Circular may have to be produced in courts, the judicial folders in the office of Pr. CsIT/ CsIT must be maintained in a systemic manner for easy retrieval.
Adverse judgments relating to the following issues should be contested on merits notwithstanding that the tax effect entailed is less than the monetary limits specified in para 3 above or there is no lax effect: (a) Where the Constitutional validity of the provisions of an Act or Rule is under challenge, or (b) Where Board's order, Notification, Instruction or Circular has been held to be illegal or ultravires, or (c) Where Revenue Audit objection in the case has been accepted by the Department, or (d) Where the addition relates to undisclosed foreign assets/ bank accounts. 11. The monetary limits specified in para 3 above shall not apply to writ matters and Direct tax matters other than Income tax.
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Filing of appeals in other Direct tax matters shall continue to be governed by relevant provisions of statute and rules. Further, in cases where the tax effect is not quantifiable or not involved, such as the case of registration of trusts or institutions under section 12A/12AA of the IT Act, 1961 etc., filing of appeal shall not be governed by the limits specified in para 3 above and decision to file appeals in such cases may be taken on merits of a particular case. 12. It is clarified that that monetary limit of Rs. 2O lakhs for filing appeals before the ITAT would apply equally to cross objections under section 253(4) of the Act. Cross objections below this monetary limit, already filed should be pursued for dismissal as withdrawn/ not pressed. Filing of cross objections below the monetary limit may not be considered henceforth. Similarly, references to High Courts and SLPs/ appeals before Supreme Coon below the monetary limit of-Rs. 50 lakhs and Rs. 1 Crore respectively should be pursued for dismissal as withdrawn/ not pressed. References before High Court and S appeals below these limits may not be considered henceforth. 13. This Circular will apply in SLPs/appeals/cross objections/ references -; be filed henceforth in SC/HCs/Tribunal and it shall also apply retrospect’s; to pending SLPs/ appeals/ cross objections/ references. Pending appeals below the specified tax limits in para 3 above may be withdrawn/ not pressed 4. Considering the above CBDT circular, we found that this appeal of the revenue is not maintainable as the tax effect in this appeal is below Rs.20 Lakhs. Accordingly, appeal of the revenue is dismissed.
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C.O. NO. 41/M/2016:-
The assessee has filed the cross-objection in the appeal of the revenue in ITA. No. 6153/M/2014. The assessee has raised the grounds of reopening u/s 147 of the Act. However, at the time of argument the assessee did not press the ground, therefore, the present ground is hereby ordered to be dismissed being not pressed. Accordingly, this cross-objection is decided in favour of the revenue against the assessee.
ITA. NO. 35/M/2014:-
The revenue has filed the present appeal against the order dated 30.10.2013 passed by the Commissioner of Income Tax (Appeals)-18, Mumbai [hereinafter referred to as the “CIT(A)”] relevant to the A.Y.2010- 11.
The revenue has raised the following grounds.: -
“i. ''Whether on the facts and in the circumstances of the case and in law, the Ld.C1T[A) erred in dealing the disallowance made u/s 24(b) towards interest of Rs.31,84,764/- paid in respect of loan taken from M/s. India Bulls Financial Services Ltd,?" ii. "Whether on the facts and in the circumstances of this case and in law, the Ld. CIT(A] erred in allowing interest u/s 24lb) of the IT Act paid on the loan taken from M/s. India Bulls Financial Services Ltd. without appreciating that the purpose of availing of these funds was not acquiring the property at Nucleus. Pune but was merely taken against the said property?" III "Whether on the facts and in the circumstances of the case and in law. the Ld. CTT(A) erred in not appreciating that in the end-use undertaking furnished by the assesses to M/s. India Bulls Financial Services Ltd at the time of sanction of the loan, it was
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clearly stated that the ban was for business expansion / working capital and that the purpose of use of funds under loan ''shall11 not be changed in any manner during the tenure of the loan or that such change in purpose "shall'1 take place only with the prior written permission of M.s, India Bulls Financial Services Ltd.?, iv. "Whether on the facts and in The circumstances of the case and in law* the Ld. ClT(A) erred in not appreciating that in the details furnished by the assesses itself during proceedings for AY 2008-09 in the form of a statement explaining the loans raised and utilization of such loans for acquisition of assets, it was clearly stated that the loan from M/s. India Bulls had been utilized for purchase of shares in two private limited companies which fact was mentioned in the assessment order?'1 v. ''Whether on the facts and in the circumstances of the case and in law, the Ld. ClT(A) erred in not appreciating that in the instant case, in the absence of specific evidence to substantiate direct utilization of loans taken from M/s. India Bulls Financial Services Ltd as having been utilized lot repayment of earlier loans which were obtained for purchase of the property, the claim of deduction u/s 24(b) made by the assessee in respect of interest on bank loan paid to the tune of Rs.31,84,764/- is not maintainable?" vi. ''Whether on the facts and in the circumstances of the case and in law, the Ld. ClT(A) erred in restricting the disallowance u/s 14A read with Rule 3D of the IT Rules To Rs.3,28,374/- without appreciating that as the loan from M/s. India Bulls Financial Services Ltd, was not availed of for the purpose of purchase of property at Nucleus, Pune. the interest of Rs,3VS4J64/- paid towards it had to the taken into account while computing expenses disallowable towards the exempt dividend income earned by the assesset-company?1' vii. "The appellant prays that the order of the ClT(A) on the above grounds be set aside and that of the A.O. be restored/' viii, "The appellant craves leave to amend or alter any grounds or add a new ground which may be necessary." 11. The brief facts of the case are that the assessee filed its return of income on 27.09.2010 declaring total income to the tune of Rs.17,56,841/-. The return was processed u/s 143(1) of the I.T. Act, 1961. Thereafter, the case was selected for scrutiny and accordingly notice u/s 143(2) of the Act dated 23.09.2011 and notice u/s 142(1) of the Act dated 20.07.2012 were
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issued and served upon the assessee. During the period, the assessee has shown the rental income. In the year under consideration, the assessee has debited the interest expenses to the tune of Rs.1,12,62,914/- to the profit & loss account. The interest of Rs.31,84,764/- claimed as deduction u/s 24 of the Act against the house property Office No. 701 & 702 at Nucleus, Pune which was paid to M/s. India Bulls Financial Services Ltd. The said property was purchased by assessee in the year 2005 and the loan from India Bulls Financial Service Ltd was taken in the year 2008. Therefore, notice was given and after reply to the notice the interest was added to the income of the assessee. The claim of the assessee u/s 14A of the Act was also assessed and Assessing Officer disallowed the expenditure to incur the exempt income to the tune of Rs.65,67,232/-. The total income of the assessee was assessed to the tune of Rs.1,15,26,671/-. Thereafter, the assessee has filed an appeal before the CIT(A) and the CIT(A) allowed the claim of the interest u/s 24B of the Act to the tune of Rs.31,84,764/- and also allowed the partly claim u/s 14A of the Act and assessed the expenditure to earn the exempt income to the tune of Rs.3,28,374/-, therefore, the revenue has filed the appeal in ITA. No.7125/M/2013 before us.
ISSUE. NO. 1:-
Under this issue the revenue has challenged the allowance of the claim of the assessee towards interest to the tune of Rs.31,84,764/- u/s 24(b) of the Act to the tune of Rs.31,84,764/- u/s 24(b) of the Act.
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Before going further, we deemed it necessary to advert the finding of the CIT(A) on record.: -
“1.3 From the perusal of the facts of the case, it is an undisputed fact that the assesses has purchased properly at Pune for a consideration of Rs,2,20,33,500/- in 2005. Secondly, A is also undisputed that as per balance-sheet of AV. 2006-07, the assessee was having only Rs.29,94, 199/-. share capital, reserves & surplus. Thus, the assessee has taken unsecured loans amounting to Rs.2,62,29,088/- which was utilizer for purchase of properly at pune it is also an undisputed issue that the assessee has received loan from M/'s. Indias Bulls Financial Services Pvt. Ltd. in the year 2008 amounting to Rs.2,04,91,51/-. The assessee has claimed that this loan received from M/s. India’s Bulls Financial Ltd. was utilized for reimbursement of unsecured loans taken for of Pune property The appellant has copies of balance-sheet for A Y. 2006- 07, source of funds for AY 2005-07 find balance sheet Tor A.Y 2010-11 and the utilization of funds for A.Y 2010-11. The appellant has also filed the credited of interest paid of Rs.1,12,62,913/- out of which Rs.60,445,288/- was suo-motu disallowed and added back to the taxable income. The amount of Rs.20,32.86 W- was claimed u/s 24 paid to M/s Citi Bank Ltd. which was allowed by the A.O. and Rs,31 ,54,7647- claimed u/s 24 paid to M/s. Financial Services ltd. which was disallowed by the A.O. 7ns A.O. has called for information vi/'s 133(6) from M/s. India Bulls Financial Service^^Ltd. in which it was confirmed that this loan was arranged by the appellant for the property Office at 701 & 702, 7th Floor, Nucleus; Pune, but in the loan application form column for 'purpose of loan1 was left blank. This was the reason that the A.O. has created a doubt that this loan was Tot utilized for purchase of Pune property But the A.O has ignored that as per the loan agreement, it is dearly mentioned that this loans has been taken for purchase of Pune property only. Secondly, the AO. has concluded 'hat no evidence was submitted for the utilization of loan taken from MVs. India Bulls Financial Services Ltd. To explain this issue, the AR of the appellant has submitted its reply and extract of balance sheet for A.Y. 2006- 07 which is reproduced by the A.O, in the assessment order itself at page 6 & 7 where li is clear that the assesses was having only funds of Rs. 29.94.199/- on account of shareholders under
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surplus reserves. Written this property was purchased in the year 2005, the assessee has taken unsecured loans of Rs.2,62,29,088/- from the family, members and friends This information was submitted before the A.O and the balance sheet for A Y. 2010-11 and (he utilization of funds tor A.Y. 2010-11 is also filed before the A.O. The payment of interest and the bifurcation is also submitted before 'the A,O, therefore, the conclusion of the A.O. that no evidence was tiled is not justifiable. The loan agreement clearly proves that it was taken for purchase of Pune property The unsecured loans utilized for purchase of this property were paid up by this loan taken from M/s. India Bulls Financial Services Ltd. clearly proves that there is a direct nexus (hat this [can was utilized for purchase of this property. Once it is established that this loan was utilized or purchase of property, therefore, the deduction u/s 24 of the I.T. ACT is allowable to the assessee. In view of these Facts & circumstances, it is held that there is a direct nexus that the assessee has. received loan from M/s. India Burls Financial Services Ltd. which was utilized for reimbursement of unsecured loans for purchase of Rune property, therefore, the disallowance made by the A.O, is not sustainable, hence deleted Ground of appeal is allowed.” 13. On appraisal of the above said finding, we noticed that AO has declined the claim of the assessee on account of this fact that no purpose has been written in the application while seeking the loan from M/s. India Bulls Financial Service Ltd. however, the AO nowhere examined the other relevant documents. The CIT(A) has gone through the each and other aspects of the case and also gone through the loan agreement which speaks about the purpose in which the loan was taken. The loan was found to be taken for purchase of property. Therefore, the deduction u/s 24 of the Act was allowed. The facts are not distinguishable at this stage. Nothing came into notice that the loan was not taken by the assessee for the purpose to purchase
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the property at Pune. It is only factual issue and according to the facts of the case, the claim of assessee u/s 24 of the Act has been allowed. On seeing the facts and circumstances of the case, we have arrived at this conclusion that the CIT(A) has passed the order judiciously and correctly which is not liable to be interfere with at this appellate stage. Accordingly, this issue is decided in favour of the assessee against the revenue. In the result, appeal filed by the revenue is hereby ordered to be dismissed. ITA. NO. 7125/M/2013:- 14. The assessee has filed the present appeal against the order dated 30.10.2013 passed by the Commissioner of Income Tax (Appeals)-18, Mumbai [hereinafter referred to as the “CIT(A)”] relevant to the A.Y.2010-11. 15. The assessee has raised the following grounds. - “1. On the facts and in the circumstances of the case and in law, the Ld. CIT(A)-18, Mumbai has erred in sustaining disallowance of Rs.3,28,374/- u/s 14A of the I.T. Act, 1961. The appellant therefore prays the penalty be deleted. Appellant craves to add, alter, amend, delete and/ or modify any or all of the aforesaid grounds of appeal either at the time of hearing or at any time before the date of hearing.”
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We have heard the argument advanced by the Ld. Representative of the parties and perused the record. Under this issue the assessee has challenged the disallowance of Rs.3,28,374/- u/s 14A of the I.T. Act, 1961. At the very outset, the Ld. Representative of the assessee has argued that the claim of the assessee be restricted to the extent of exempt income i.e. to the tune of Rs.1,12,500/-. In view of the submission made by the assessee and in view of the law settled in by the Delhi High Court in the case of case of Joint Investment Private Limited in ITA.No. 117/15 dated 25.02.2015, we restricted the expenses incurred to earn the exempt income to the extent of dividend income i.e. to the tune of Rs.1,12,500/-. Accordingly, the issue has decided in favour of the assessee against the revenue.
In the result, appeal filed by the revenue is hereby dismissed and appeal filed by the assessee is hereby ordered to be partly allowed. Order pronounced in the open court on 31.07.2018. Sd/- Sd/- (R. C. SHARMA) (AMARJIT SINGH) लेखा सदस्य / ACCOUNTANT MEMBER न्यधनिक सदस्य/JUDICIAL MEMBER मुंबई Mumbai ददनांक Dated : 31.07.2018 Vijay
आदेश की प्रनिनिनि अग्रेनर्ि/Copy of the Order forwarded to : 1. अपीलाथी / The Appellant 2. प्रत्यथी / The Respondent.
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आयकर आयुक्त(अपील) / The CIT(A)- 4. आयकर आयुक्त / CIT 5. दवभागीय प्रदतदनदि, आयकर अपीलीय अदिकरण, मुंबई / DR, ITAT, Mumbai 6. गार्ड फाईल / Guard file. आदेशधिुसधर/ BY ORDER, सत्यादपत प्रदत //True Copy// उि/सहधिक िंजीकधर /(Dy./Asstt. Registrar) आिकर अिीिीि अनर्करण, मुंबई / ITAT, Mumbai