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Income Tax Appellate Tribunal, “A” BENCH : KOLKATA
Before: Hon’ble Sri N.V.Vasudevan, JM & Shri Waseem Ahmed, AM ]
IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : KOLKATA [Before Hon’ble Sri N.V.Vasudevan, JM & Shri Waseem Ahmed, AM ]
I.T.A No. 2754/Kol/2013 Assessment Year : 1999-2000
D.C.I.T., Circle-11, -vs.- M/s. Bishwanath Tea Co.Ltd. Kolkata Kolkata (Appellant) [PAN : AAACE5778N] (Respondent)
For the Appellant : Shri Rajat Kumar Kureel, JCIT, Sr.DR For the Respondent : Shri D.S.Damle, FCA
Date of Hearing : 19.01.2017. Date of Pronouncement : 03.02.2017. ORDER Per N.V.Vasudevan, JM
This is an appeal by the Revenue against the order dated 09.09.2013 of CIT(A)-XII, Kolkata relating to A.Y.1999-2000.
The Assessee is a company engaged in the business of growing and manufacture and sale of tea. Under the Income Tax Act, 1961 (Act), Agricultural Income is not chargeable to tax. Agricultural income has been defined in Sec.2(1A) of the Act. For incomes which are partially agricultural income and partially non-agricultural income rules have been provided in the Income Tax Rules, 1962 (Rules). The definition of agricultural income and relevant rules are considered as integral part for the purpose of ascertaining what is agricultural income. Agricultural income is basically rent for agricultural land and also income derived from sale of agricultural produce raised by cultivation of land. Sometimes apart from growing agricultural produce, certain other processes (other than usual minimum processes to render produce marketable) are carried out by an Assessee. The income derived from sale of such produce i.e., from sale of such manufactured produce is considered partially agricultural income and partially business income. For example a grower of tea in his tea gardens carries out the process of manufacturing tea powder from tea leaves grown ITA No.2754/Kol/2013 – M/s. Bishwanath Tea Co. Ltd. A.Y.1999-2000 1
in his garden. In such case the income from sale of tea powder will be partly agricultural income and partly non-agricultural income chargeable to tax. This is referred to as Composite Income because it composes of both Agricultural and non- Agricultural income. When some extra processes are carried out for selling the produce, there is combination of manufacturing activities, in which case income from sale of manufactured agricultural produce is computed as if it is business income and certain percentage is considered as chargeable under Act. Part II under Sub-Part D of the Rules prescribes the rules for the manner of determination of income chargeable to tax from and out of the Composite Income. Rule 7, 7A, 7B and 8 of the Rules deal with such computation. Rule 8(1) of the Rules is relevant for the present case and it deals with determination of income from manufacture and sale of tea and it reads thus:
“Rule-8. (1) Income derived from the sale of tea grown and manufactured by the seller in India shall be computed as if it were income derived from business, and forty per cent of such income shall be deemed to be income liable to tax.” 3. For AY 1999-2000 the Assessee filed return of income on 31.12.1999 declaring total income of Rs.10,54,32,770/-. An order of assessment u/s.143(3) of the Act was passed on 27.3.2002. One of the issue that arose for consideration before the AO in the assessment proceedings was the deduction allowable u/s.33AB of the Act. Sec.33AB of the Act reads as follows: “Sec.33AB. (1) Where an assessee carrying on business of growing and manufacturing tea or coffee or rubber in India has, before the expiry of six months from the end of the previous year or before the due date of furnishing the return of his income, whichever is earlier,— (a) deposited with the National Bank any amount or amounts in an account (hereafter in this section referred to as the special account) maintained by the assessee with that Bank in accordance with, and for the purposes specified in, a scheme (hereafter in this section referred to as the scheme) approved in this behalf by the Tea Board or the Coffee Board or the Rubber Board; or (b) deposited any amount in an account (hereafter in this section referred to as the Deposit Account) opened by the assessee in accordance with, and for the purposes specified in, a scheme framed by the Tea Board or the Coffee Board or the Rubber Board, as the case may be (hereafter in this section referred to as the deposit scheme), with the previous approval of the Central Government,
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the assessee shall, subject to the provisions of this section, be allowed a deduction (such deduction being allowed before the loss, if any, brought forward from earlier years is set off under section 72) of— (a) a sum equal to the amount or the aggregate of the amounts so deposited ; or (b) a sum equal to forty per cent of the profits of such business (computed under the head "Profits and gains of business or profession" before making any deduction under this section), whichever is less :” 4. In the course of the said assessment proceedings the assessee had furnished details of incomes credited in the profit & loss account under different nomenclatures such as income from investments, profit on sale of investments miscellaneous income, liabilities no longer required written back etc. In the return filed for the AY 1999-00 the appellant had claimed deduction u/s 33AB of the I T Act. In arriving at the deduction permissible u/s 33AB the assessee had taken into account income by way of Misc. income and Liabilities no longer required written back both amounting to Rs. 108.07 lacs. 20% of such income was considered to be part of the qualifying amount for the claim of deduction u/s 33A.B of the Act. In para 13 of the assessment order dated 27.03.2002 the AO recorded the following finding.
“13. Calculation of deduction under Section 33AB : The deduction under Sec 33AB is allowable only on the composite income earned by growing and manufacturing of tea. Hence, for the purpose of calculation of admissible deduction all the income not incidental to growing and manufacturing of tea have been deducted from the composite income of the tea business. The calculation is annexed with the order.” 5. The deduction permissible u/s 33AB was then worked out by the AO in the following manner:-
ANNEXURE Admissible deduction u/s 33AB Computation of admissible deduction u/s 33AB Rs. (A) Total income computed before 33AB 31.51.75,850 Less: As discussed in the body of order (income not incidental to growing & ITA No.2754/Kol/2013 – M/s. Bishwanath Tea Co. Ltd. A.Y.1999-2000 3
manufacturing of tea, other than those deducted in computation) (1) Income from Investments (Rs.2,35,79,000/ dividend income of Rs.1, 11 ,89,966) (2) Profit on sale of investment: Rs.63,15,000 - (3) Miscellaneous income: Rs.97,39,000- (4) Liability no longer required to be written back Rs.10,68,000/- 2,95,11,034 28,56,64,816 20% of above 5,71,32,963 Amount deposited with NABARD (as per certificate) 5,80,00,000 Admissible deduction: 5,71,32,963”
It can be seen from the aforesaid discussion of the AO in the order of Assessment dated 27.3.2002 passed u/s 143(3) of the Act, together with its Annexure thereto that the AO had applied his mind to nature of various receipts and incomes which the assessee had credited in its Profit & Loss Account and the question whether they could form part of the composite income. After considering the relevant facts and the nature of income, the AO had held that the income credited under the head Misc. income and liabilities no longer required written back did not form part of the composite income derived from growing and manufacture of tea. On that ground he excluded these and some other receipts while working out the qualifying profits from which deduction u/s 33AB was allowed. These facts go to show that the assessee had not only made full disclosure of its income credited under the head Misc. income and liabilities no longer required written back but the AO himself had also applied his mind with regard to the nature of income credited by the assessee.
The AO issued a notice u/s.148 of the Act for making an assessment u/s.147 of the Act on 21.2.2005 after recording the following reasons:
“The case was scrutinised u/s.143(3) on 27.03.02. Subsequently, on perusal of record it reveals that the assessee had credited in its P&L a/c. Miscellaneous income of Rs.l 08.07 lakhs. This amount was included in the composite income from tea growing and manufacturing. This consists of two items, namely Miscellaneous income of Rs.97.39 lakhs & Liability no longer required, written ITA No.2754/Kol/2013 – M/s. Bishwanath Tea Co. Ltd. A.Y.1999-2000 4
back amounting to Rs.10.68 lakhs as apparent from Schedule-12 of the P&L a/c. Subsequently, in the computation the assessee had not offered the Misc. income @ 100% for taxation. The assessee had subjected only 40% of the aforesaid Misc. income of Rs.108.07Iakhs for Income tax. Obviously, the rule- 8 regarding apportionment of income applies only to the income from tea growing and manufacturing, the entire amount of Rs.108.07 lakhs was required to be subjected to tax instead of restricting it to 40%. In view of the above, there was reason to believe that there had been an escapement of income for the failure on the part of the assessee for offering entire Miscellaneous income for Income tax in the computation within the meaning of Section-147 of the I.T.Act,1961.”
As can be seen from the above reasons recorded by the AO before issue of notice u/s.148 of the Act, the AO has referred to two items of income viz., Miscellaneous Income of Rs.97.39 Lakhs and liability no longer required and hence written back of Rs.108.07 lakhs. According to the AO these items of income ought not to have been considered as part of the composite income when Rule 8(1) of the Rules was applied in the assessment concluded u/s.143(3) of the Act and therefore there was escapement of income.
The details of these two items of income are as follows:
Details of miscellaneous incomes Rs. Received from Insurance Company A/c Flood Claim 10,84,389.00 Received from Insurance Company A/c Fire Claim 33,15,427.00 Received from Insurance Company A/c Storm Damage 79,534.00 Received from Insurance Company A/c Elephant Damage 8,66,436.00 Received on account of Guest House 34,88,000.00 Sale of Scrap and Old Gunny Bags 9,04,998.34 [A] 97,38,784.34 Details of Liabilities no longer required written back Name of the Tea Estate On account of Rs. Mijcanjan Tea Estate Land Revenue 2,73,853.00 Romai Tea Estate Land Revenue 60,780.00 ITA No.2754/Kol/2013 – M/s. Bishwanath Tea Co. Ltd. A.Y.1999-2000 5
Dufflaghur Tea Estate Land Revenue 3,32,480.00 Mahanhkali Tea Estate Land Revenue 4,00,329.00 [B] 10,67,442.00 Miscellaneous Income [A + B] 1,08,06,226.00 10. The Assessee explained before the AO in the reassessment proceedings that all the aforesaid income were inextricably connected with the business of growing and manufacturing of tea and therefore had to be regarded as part of the composite income for the purpose of applying Rule 8 (1) of the Rules. The nature of the expenses were explained by the Assessee thus:
“(a)Rs.53,45.786/- relates to recovery from the insurance claims against the loss of business assets incurred by assessee at different tea-gardens as given in the Annexure. (b) An amount of Rs.34,88,000 relates to the realization of expenses for use of the guest house. (c) The balance' amount of Rs.9,04,988/- is related to sale of scrap and old gunny bags at Gardens and Head Office which are regular business assets of the assessee utilized for the purpose of growing and manufacturing of tea. A) As to the receipts of insurance claim it will be evident from the Annexure 'A' that realization was made against fire claim, loss of crops and fencing due to the onslaught of elephants in the gardens. Similar losses occurred due to storms and hails, and also due to flash-flood which some time occurs in the garden area. These losses are revenue in nature, which were duly debited in the accounts of the Assessee in the earlier year. Against these losses, the Assessee lodged claim before the insurance authority who allowed the claim to the extent of Rs.53,45,786/- only. The Insurance Authority duly made enquiry & inspection in the gardens before. The acceded to the claim of the assessee for losses. You will agree that, as the losses are revenue in nature incurred in course of growing and manufacturing of tea, these receipts being part of the income of the Assessee from growing and manufacturing of tea is the part of the composite income as well. The recoveries from insurance claim is part of the composite income of growing and manufacturing is being entitled to be apportioned in the ratio of 40 : 60 as provided under rule-8 of the Income Tax Rules, 1962. B) Regarding receipts of income from guest house at Rs. 34, 88, 000/-, we are to submit that this is the amount of realization of actual expenditure incurred by the assessee for maintenance and repairing of the assets of the guest house. These realizations were made from the persons and group companies who use ITA No.2754/Kol/2013 – M/s. Bishwanath Tea Co. Ltd. A.Y.1999-2000 6
the guest house from time to time. Against the above realization of Rs. 34,88,000/-, the assessee incurred an expenditure of Rs. 34, 92, 080/- which are debited in the respectively heads of accounts. It is evident that out of the realization from guest house, the assessee incurred loss and there is no assessable income from realization. Therefore, the composite income determined does not include any profit from maintenance and user of the guest house by the other associated companies. C) As regards the sale scrap and ole gunny bags at Rs.9,04,998/- we are to submit that in the tea gardens there are regular sale of unusable goods which are procured from time to time for running of the business for growing and manufacturing of tea. Expenses incurred for procurement of such items are included in the purchases account of the gardens and regularly debited in the profit & loss account. The sales of such unusable left-outs are also part of the activities of growing and manufacturing of tea. The sale proceeds of such items are credited in the profit & loss account and the same is included in the composite income of growing and manufacturing of tea. Essentially, they require to be apportioned in the ratio of 40 : 60 as provided under rule-8 of the Income Tax Rule,1962. LIABILITIES NO LONGER REQUIRED - WRITTEN BACK In the profit & loss account sum of Rs. 10,67,442/- has been credited under this head. The details of above amount has been given in annexure- 'A’ as referred to earlier. From the details you may please find that the amount written back relates to account of land-revenue in respect of different tea gardens. Payments of land-revenue relating to the gardens as mentioned in annexure- 'A ' was debited in the profit and loss account in the earlier years. The actual amount of demand raised by the Land-Revenue Officer were less than the expenses debited in the earlier years hence been written back. Payments of land-revenue is part & parcel of the activities of the assessee as grower and manufacturer of tea. The expenses debited in profit and loss account in the earlier years were also allowed while determining the composite income of assessee as a grower and manufacturer of tea. Now the excess payment which has been written back on account of land-revenue is also part of the activities of the assessee as grower and manufacturer of tea. Evidently, this income from the part of the composite income from growing and manufacturing of tea. ” 11. The AO was however observed in the order of assessment u/s.147 of the Act that the Assessee was asked to produce ledger a/cs and supporting documents but the Assessee produced only ledger a/cs. According to the AO the assessee has not conclusively proved that the aforesaid items of incomes relate to income from ITA No.2754/Kol/2013 – M/s. Bishwanath Tea Co. Ltd. A.Y.1999-2000 7
growing and manufacturing of tea. Therefore, he concluded that the Misc. income of Rs.I08.07 lacs is not incidental to income from tea growing and manufacturing. The AO has not made any reference to the miscellaneous income of Rs.97.39 in his order. The AO finally concluded the Assessment u/s.147 of the Act as follows:
“As per discussion above, the total income of the assessee-company is re- computed as follows : 100 % Composite Income as per order u/s.254/251/143(3), dt.l3.03.06 Rs.22,46,23,244/- Less : Income from business( as discussed above) Rs. 1,08,70,000/- Rs.21,37,53,244/- Applying Rule-S (40% of above) Rs. 8,55,01,298/- Add: Profit attributable to sale of tea manufactured out of green leave purchased Rs. 52,13,889/- Add: Income from business (as discussed above) Rs. 1,08,70,000/- Total Business income Rs.10, 15,85, 187/- Add : Income from other source as per computation in the order u/s.143(3) Rs. 5,17,02,569/- Gross Total income Rs.15,32,87,756/-”
Aggrieved by the order of the AO the assessee preferred an appeal before CIT(A). The assessee objected to the legality and validity of re-assessment proceedings broadly on two counts; (i) against the initiation proceedings under sec. 147 and issue of notice under sec. 148 of the Act and (ii) against the completion of assessment under sec. 143(3) of the Act without issue of statutory notice under sec. 143(2) of the Act.
As regards the first point, it was submitted that the original assessment was completed u/s 143(3) on 27.03.2002. Period of 4 years from the end of the AY 1999- 00 would end on 31 .03.2004. As per the first proviso to Sec 147 of the Act, reopening of assessment after 4 years from the end of the relevant AY in a case where assessment has already been completed u/s.143(3) of the Act was permissible if and only if the income had escaped assessment as a result of assessee’s failure to disclose truly and fully all material facts necessary for assessment. It was contended that in the recorded reasons, there is no suggestion, even remotely, that at the time of completion of the original assessment, there was any failure on the Assessee to disclose truly and ITA No.2754/Kol/2013 – M/s. Bishwanath Tea Co. Ltd. A.Y.1999-2000 8
fully all material facts necessary for its assessment for AY 1999-00. It was further contended that re- assessment proceedings after 31 .03.2004 therefore could not have been initiated by the AO. In the circumstances the AO was legally not permitted to reopen the concluded assessment in view of the first proviso to Sec i 47 of the Act.
It was further submitted that for AY 1999-00 the assessment was originally completed u/s 143(3) on 27.03.2002. The said order was passed after detailed examination of the Assessee's books of account; details, documents and the explanations as requisitioned by the Assessing Officer in the course of assessment proceedings. In the return filed for the AY 1999-00 the Assessee had claimed deduction u/s 33AB of the Act. It was also submitted that in arriving at the deduction permissible u/s 33AB of the Act, the Assessee had taken into account income by way of Misc. income and Liabilities no longer required written back both amounting to Rs. 108.07 lacs. 20% of such income was considered to be part of the qualifying amount for the claim of deduction u/s 33AB of the Act. The AO in para 13 of the original assessment order dated 27.03.2002 which we have extracted in the earlier part of this order, has recorded the claim of the Assessee in this regard and had computed admissible deduction under sec. 33AB of the Act. It was therefore submitted that reassessment proceedings were initiated by the AO purely on the same set of facts which existed when the original assessment proceedings were concluded and without any fresh material coming to his possession. In other words it was submitted that the reassessment proceedings have been initiated by the Assessing Officer, upon change of opinion that 100% of the Misc. income was liable to be excluded from the Composite income. It was contended that reopening on such change of opinion was legally unjustified because such reopening did not satisfy the conditions enshrined in the Sec 147 of the I.T. Act viz., reason to believe that income chargeable to tax has escaped assessment. Reliance was placed by the Assessee on the ratio laid down in the following decisions:
(i) Rajesh Jhaveri Stock Broking Pvt. Ltd Vs. CIT (291 ITR 500)(SC) (ii) CIT Vs. Foramers France (264 ITR 566) (SC) (iii) Kelvinators of India Ltd (256 ITR 1) (Del) affirmed in (320 ITR 561) ITA No.2754/Kol/2013 – M/s. Bishwanath Tea Co. Ltd. A.Y.1999-2000 9
(iv) CIT vs Usha International Ltd. (348 ITR 485) (Del) The CIT(A) held that the re-assessment proceedings had been initiated after a period of four years from the end of the relevant assessment year and since the assessment u/s 143(3) of the Act had already been made initiation of re-assessment proceedings u/s 147 of the Act should satisfy the requirements of the proviso to section 147 namely there should be a failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment of that year. The CIT(A) held that the assessee had duly disclosed all material facts and therefore the condition laid down in the proviso to section 147 was not satisfied.
The CIT(A) also held that during the conclusion of the original assessment proceedings no new material came to the possession of the AO on the basis of which he could entertain relief regarding escapement of income. The CIT(A) held that re- assessment proceedings were initiated purely on the basis of change of opinion and therefore initiation of re-assessment proceedings was not valid in law. The CIT(A) also held that there was no service of notice u/s 143(2) of the Act on the assessee in the re-assessment proceedings after the assessee had filed the return of income in response to the notice u/s 147 of the Act. The CIT(A) held that non service of notice u/s 143(2) of the Act before completion of re-assessment proceedings u/s 147 of the Act was not a procedural irregularity and mandatory requirement for validity of order of re-assessment. In coming to the above conclusion the CIT(A) placed reliance on the decision of the Hon’ble Supreme Court in the case of ACIT vs Hotel Blue Moon 321 ITR 362 (SC). The CIT(A) accordingly held that non issue of notice u/s 143(2) of the Act by the AO on the assessee on his filing of return of income u/s 148 of the Act rendered the order of re-assessment illegal and void. The CIT(A)also held that the miscellaneous income had nexus with the activity of the growing and manufacturing of tea and therefore had to be regarded as part of the composite income from growing and manufacturing of tea.
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Aggrieved by the order of CIT(A) the revenue has filed the present appeal before the Tribunal. The revenue has filed the revised grounds of appeal before the Tribunal and the same reads as follows :-
“(i) That on the facts and in the circumstances of the case and as per law Id. CIT(A) erred in giving the judgement that the re-assessment proceeding u/s 147 is invalid because no notice u/s 143(2) was issued before completion of assessment u/s 147/143(3). (ii) That on the facts and in the circumstances of the case and as per law Id. CIT(A) erred in giving the judgement the re-assessment proceedings u/s 147 is invalid because re-assessment proceeding has been started after expiry of 4 years and no fresh material on record to believe that escapement of income has occurred." (iii) That on the facts and in the circumstances of the case, Ld. CIT(A) erred in observing that the recovery of Insurance claim of Rs. 53,45,786/- is part of the income derived from the assessee business of growing and manufacturing of tea for the purpose of computation of composite income for application of Rule 8. (iv) That on the facts and in the circumstances of the case, Ld. CIT(A) erred in observing that the sale of scrap of Rs. 9,04,998/- is part of the income derived from the assessee business of growing and manufacturing of tea for the purpose of computation of composite income for application of Rule 8. (v) That on the facts and in the circumstances of the case, Ld. CIT(A) erred in observing that the Guest House Receipts of Rs.34,88,000/- is part of the income derived from the assessee business of growing and manufacturing of tea for the purpose of computation of composite income for application of Rule 8. (vi) That on the facts and in the circumstances of the case, Ld. CIT(A) erred in observing that the liabilities written back of Rs. 10,67,442/- is part of the income derived from the assessee business of growing and manufacturing of tea for the purpose of computation of composite income for application of Rule 8. (vii) That the appellant craves leave to add, alter/or amend any of the grounds of appeal during the course of hearing.”
We have heard the submissions of the ld. Counsel for the assessee and the ld. DR. The ld. DR relied on the order of AO while the ld. Counsel for the assessee brought to our notice that even in the revised grounds of appeal the revenue has not challenged the order of CIT(A) whereby the CIT(A) held that initiation of re-assessment proceedings is not valid for the reason that re-assessment proceedings were initiated
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purely on the basis of change of opinion. The ld. Counsel for the assessee relied on the order of CIT(A) in respect of the other grounds of appeal of revenue.
We have given a very careful consideration to the rival submissions. It is clear from the order of CIT(A) that the question whether miscellaneous income of Rs.108.08 lakhs would form part of the composite income for the purpose of section 33AB of the Act was fully investigated by the AO while concluding the assessment proceedings u/s 143(3) of the Act. Therefore the AO was fully conscious of miscellaneous income of Rs.97.39 lakhs as well as the fact with regard to the income arising on account of written back of liabilities u/s 41(1) of the Act. The basis of claiming that a particular income is part of the composite income under Rule 8(1) as well as section 33AB of the Act are same, viz., there connection with the business of growing and manufacture of tea. In these circumstances it cannot be said that there was any failure on the part of the assessee to fully and truly disclosed all material facts for completion of the assessee for that assessment year. Admittedly prior to the initiation of re-assessment proceedings u/s 147 of the Act an order of assessment for the relevant assessment year had been passed u/s 143(3) of the Act. The re-assessment proceedings were initiated admittedly beyond the period of four years from the end of the relevant assessment year. In these circumstances for valid initiation of re- assessment proceedings u/s 147 of the Act the conditions laid down in the proviso to section 147 of the Act had to be satisfied, viz., escapement of income should be as a result of the assessee’s failure to disclose truly and fully material facts necessary for assessment/income for the relevant assessment year. Since this condition has not been satisfied in the present case, the CIT(A) was fully justified in concluding that re- assessment proceedings were not validly initiated. Since the initiation of re- assessment proceedings have been held to be invalid and therefore the reassessment order is liable to annulled, we do not wish to deal with other grounds with regard to the re-assessment proceedings having been initiated on a change of opinion and the arguments that no notice u/s 143(2) of the Act in the re-assessment proceedings were issued and therefore re-assessment proceedings are invalid. We also do not wish to go
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into the question as to whether the disputed items of income could form part of the composite income of the assessee or not for the purpose of Rule 8(1) of the Rules.
For the reasons given above we do not find any merits in the appeal of the revenue and the same is dismissed.
In the result the appeal of the revenue is dismissed.
Order pronounced in the Court on 03.02.2017.
Sd/- Sd/- [Waseem Ahmed] [ N.V.Vasudevan ] Accountant Member Judicial Member
Dated : 03.02.2017.
[RG PS]
Copy of the order forwarded to:
M/s. Bishwanath Tea Co. Ltd., 4, Mangoe Lane, Kolkata-700001. 2. D.C.I.T., Circle-11, Kolkata. 3. CIT(A)-XII, Kolkata 4. CIT – IV, Kolkata. 5..CIT(DR), Kolkata Benches, Kolkata.