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Income Tax Appellate Tribunal, “K ” BENCH, MUMBAI
Before: SHRI RAJENDRA & SHRI C.N. PRASAD
सुनवाई क" तार"ख / Date of Hearing :25.04.2016 घोषणा क" तार"ख /Date of Pronouncement :22.07.2016 आदेश / O R D E R PER C.N. PRASAD, JM:
These appeals are filed by the Revenue and the assessee against the order of the Ld. CIT(A)-15, Mumbai pertaining to assessment years 2004-05 & 2005-06. – A.Y. 2004-05
The first issue in the appeal of the Revenue is that the Ld. CIT(A) erred in deleting the addition made by the Assessing Officer in respect of bills pertaining to earlier period.
Brief facts are that the Assessing Officer while completing the assessment required the assessee to explain as to why repairs and maintenance expenses amounting to Rs. 3,08,100/- should not be disallowed as these expenses were incurred in earlier years not relevant to this assessment year. The assessee submitted that following mercantile system, the bills pertaining to a year not received before finalization of accounts for that year, an accrual is made based on services rendered and estimate of how much is payable for that service. The provisions for expenses at the end of 3 M/s. Dow Chemical International Pvt. Ltd. the year are checked and audited by the statutory auditors and they signed off only because these appear to be reasonable at the end of the year. It was contended that all major significant expenses are accrued, there is a possibility that a few insignificant expenses considering the size of the company may not have been accrued. These expenses cannot be considered to be prior period expenses as it follows mercantile system of accounting and there is always a possibility of an extra/short provision of expenses. Without appreciating the submissions, the Assessing Officer disallowed the said expenditure.
On appeal, the Ld. CIT(A) deleted the disallowance made by the Assessing Officer.
The Ld. Departmental Representative places reliance on the orders of the Assessing Officer disallowing the prior period expenses.
The Ld. Counsel for the assessee submits that books of accounts of the company have been audited by the auditors and they have not made any comments on these prior period expenses. The Ld. Counsel for the assessee submits that the liability got crystallized later on as certain bills were received at the end of accounting year.
We have heard the submissions and perused the orders of the authorities below. The Ld. CIT(A) deleted the disallowance observing that assessee is a company having huge turnover and claiming expenses of crores of rupees and therefore it is not justified to doubt a sum of only Rs. 3,08,100/- as prior period expenses. The assessee has pointed out that bills in respect of the same were received 4 M/s. Dow Chemical International Pvt. Ltd. afterwards and the liability got crystallized in this Assessment Year. He also observed that there is no difference in rate of taxes it makes no difference as expenses are booked in subsequent year on receiving bills. In view of smallness of the expenditure, we are not inclined to disturb the findings of the Ld. CIT(A) on this issue. Thus we sustain the order of the Ld. CIT(A).
The next issue in the appeal of the revenue is that the Ld. CIT(A) erred in deleting the addition relating to computer expenses paid to group companies of the assessee.
8.1. Brief facts are that the Assessing Officer while completing the assessment required the assessee to furnish the details of TDS deducted on the payments made by the assessee towards computer related expenses. The assessee vide its submission dated 20.11.2006 stated to have submitted the details of various services rendered and allocation of costs and the withholding tax deducted. However, the Assessing Officer in the assessment order observed that details furnished by the assessee found that neither the break-up of such expenses filed nor the bills for the aforesaid expenses were filed. He also stated that even the calculation for arriving of the amounts were not submitted despite specifically called for. Since assessee has not furnished any details in the format provided by the Assessing Officer in the notice dated 4.8.2006 and the copies of bills were not furnished and since assessee did not establish incurring of expenditure, the Assessing Officer disallowed the computer related expenses of Rs. 82,46,109/- and added back to the income return. The Ld. CIT(A) deleted the disallowance observing that these payments made by the assessee to the AE towards computer related 5 M/s. Dow Chemical International Pvt. Ltd. expenses have already been held by the TPO to be at arm’s length and therefore there cannot be any question of disallowance of such expenses by the Assessing Officer.
8.2. The Ld. Departmental Representative submits that the role of the TPO is only to determine ALP of the transactions and the role of the Assessing Officer is to see the genuineness of the expenditure incurred by the assessee. He submits that from the TPO’s order, genuineness does not flow. Therefore he submits that the matter may be restored back to the file of the TPO/AO for fresh consideration.
8.3. The Ld. Counsel for the assessee submits that it is the business decision of the assessee to avail services from the Associated Enterprises. The TPO has examined these expenses incurred by the assessee and accepted that they are at arm’s length. The Ld. Counsel for the assessee further submits that it is the contention of the Assessing Officer that why the services were availed only from Associated Enterprises which is totally against the principles of business decisions taken by the management. The Assessing Officer cannot question its business decision of the assessee from whom the services to be rendered rather it amounts to suggesting from whom the assessee has to conduct the business. The Ld. Counsel for the assessee vehemently supports the orders of the Ld. CIT(A) in deleting the disallowance.
8.4. We have heard the rival contentions and perused the orders of the authorities below. The Assessing Officer contents that the assessee has not furnished details in respect of the expenses incurred 6 M/s. Dow Chemical International Pvt. Ltd. towards computer related expenses, bills were also not produced. However, the contention of the assessee was that these transactions have been examined by the TPO and held that they are at arm’s length, therefore, there is no necessity for the Assessing Officer to go into the transactions again. The Ld. CIT(A) considering the submissions of the assessee and the averments of the Assessing Officer deleted the disallowance observing as under:
I have considered the facts of the case and submissions of the Assessing Officer and the appellant company. Appellant’s argument is correct that payments made to group companies for computer related services, represent the share of the appellant for use of integrated system and do not represent the cost of computers. Since the payments made to AEs for this has already been held by the TPO to be at arm’s length, there cannot be any question of disallowance of such expenses by the Assessing Officer and that to on a ground like that the assessee should have availed these services locally and not through AEs stationed abroad. It is not appropriate for the Assessing Officer to step into the shoes of the taxpayer and decide what he should do or not do in his business. The role of the Assessing Officer is confirmed to administering the provisions of the Act. In any case there was no ground to revise this issue where the TPO had held that the transaction was at arm’s length. Accordingly, the addition made by the Assessing Officer is hereby deleted 8.5. On going through the order of the Ld. CIT(A) , we do not find any valid reason for interfering in the findings of the Ld. CIT(A) in deleting the disallowance. Thus, we sustain the order of the Ld. CIT(A) on this issue.
The next issue in the appeal of the Revenue is that the Ld. CIT(A) erred in deleting the addition/disallowance made in respect of rent and service charges.
7 M/s. Dow Chemical International Pvt. Ltd. 9.1. Brief facts are that the Assessing Officer in the course of assessment proceedings noticed that assessee debited Rs. 1,60,33,533/- in the profit and loss account towards rent and service charges. The assessee filed details stating that as per the service agreement, assessee incurred Rs. 54,92,400/- and as per Leave/Licence agreement it had incurred Rs. 12,27,480/- for renting the premises and utilizing various other services from the landlord viz., Godrej Soaps Ltd. The Assessing Officer took note of the fact that service charges paid by the assessee are much more than the rent, the service charges were restricted to the rent payable by the assessee and disallowed the balance service charges of Rs. 42,64,920/- observing that these service charges paid by the assessee are exorbitant and unrealistic. On appeal, the Ld. CIT(A) deleted the disallowance.
9.2. The Ld. Departmental Representative vehemently supports the orders of the Assessing Officer in restricting service charges to the rental income paid by the assessee.
9.3. The Ld. Counsel for the assessee submits that it is the conscious business decision of the assessee to pay service charges and rental income and entered into two separate agreements with the landlord. Referring to page-251 of the Paper Book containing the service agreement submits that this amount of service charges was paid for various services rendered by the landlord viz., • Security arrangement around the Licenced Premises. • General maintenance, cleanliness and upkeep of the common arease in and around the Licenced Premises. • Repair common areas around the Licenced Premises.
8 M/s. Dow Chemical International Pvt. Ltd. • Provision of water, sewage and electricity supply connection upto the Licenced Premises.
• Provide the Licencee for use by it and/or its directors, officers, invitees, visitors and customers, 6 nos. (six nos.) car parking spaces for parking light motor vehicles in the places earmarked near the Licenced Premises.
• Maintain the said parking spaces lighted at all reasonable times.
• Allow entry of lorries and other vehicles for transport of material to and from the Licenced Premises as per the business requirement of the Licencee.
Therefore, the Ld. Counsel for the assessee submits that since the assessee has taken a conscious business decision to pay service charges and also the rent, simply because the service charges paid are more than the rent, it cannot be presumed that the payment is exorbitant and unrealistic, therefore there is no justification in disallowing the service charges over and above the rental income.
9.4. We have heard the rival contentions and perused the orders of the authorities below. The Assessing Officer was of the view that the expenses paid towards service charges are much more than the rental income and therefore unrealistic hence restricted the service charges to the extent of rental income received by the assessee. The Ld. CIT(A) deleted the disallowance of rental charges observing that it is only the recipient had merely bifurcated the payment and if at all any issue arises in respect of head of income is to be assessed, it would be at the end of the recipient i.e. Godrej Soaps Ltd., but the assessee had incurred legitimate business expenditure while taking the premises on rent for its business from and independent party 9 M/s. Dow Chemical International Pvt. Ltd. (Godrej Soaps). Therefore, these expenses does not warrant any disallowance. Thus, he deleted the disallowance. We agree with the view taken by the Ld. CIT(A). It is not the case of the Assessing Officer that assessee had not incurred any expenditure at all and these service charges are paid for no services at all. The main reason for disallowing the said charges for the Assessing Officer is that since service charges paid are more than the rental income the assessee should not have incurred so much of expenditure towards service charges. Here we find that the assessee has taken a conscious decision to take on rent from Godrej Soaps Ltd., which is a third party by paying rent as well as service charges by entering into separate agreements and the lessor provided various services as enumerated in the agreement for which service charges were paid. Therefore, for the simple reason that the service charges are more than the rental income, the expenditure cannot be restricted to the rental income. Thus, we direct the Assessing Officer to delete the disallowance made towards rent and service charges.
The next issue is regarding Transfer Pricing Adjustment and Assessing Officer is challenging the order of the Ld. CIT(A) in deciding that there would not be any adjustments made to the total income in respect of the international transactions.
10.1. The assessee’s business primarily consists of importing finished goods from its Associated Enterprises (AEs) for resale to customers in India. Apart from the business of trading in chemicals, assessee assists its AEs in making direct sales in India. In other words, the assessee acts as a sales promoter on behalf of its AE for sale of chemicals, plastics and other products and it receives 10 M/s. Dow Chemical International Pvt. Ltd. indenting commission on such sales made by the AEs. During the Assessment Year, the assessee entered into following international transactions with its AE. i) Import of chemicals ii) Export of chemicals iii) Provision of Indenting services iv) Provision of software services and v) Receipt of Administrative/technical services.
10.2. The TPO made an adjustment of Rs. 9,03,19,798/- to the arm’s length price of the international transaction of provision of indenting services of the assessee holding that the gross rate of commission received under indenting activity should be same as the net margins earned in trading activity. The TPO disregarded the contention of the assessee that the indenting activity is a separate business activity as compared to trading business. The TPO rejected the analysis of the assessee and concluded that the gross rate of commission received on indenting services should be equivalent to net margins earned from trading activity. Thus, the Assessing Officer made Transfer Pricing adjustment of Rs. 9,03,19,798/- as proposed by the TPO in the assessment order.
10.3. On appeal, the Ld. CIT(A) deleted the adjustment made by the TPO observing that it is inappropriate to compare these two activities of purchase and sales i.e. trading and indenting activities. The Ld. CIT(A) also observed that the gross rate at which the assessee earns commission for indenting activities cannot be compared to the net profit, the assessee makes in the trading business. He also taken note of the submissions of the assessee that the products traded by the 11 M/s. Dow Chemical International Pvt. Ltd. assessee are different to the products on which the commission earned from its AEs are also different.
10.4. The Ld. Departmental Representative vehemently supports the order of the TPO and Assessing Officer for making TP adjustments.
10.5. The Ld. Counsel for the assessee reiterated the submissions made before the Ld. CIT(A). The Ld. Counsel for the assessee further submitted as under:
1) The learned Transfer Pricing Officer (TPO'), without questioning the economic analysis undertaken by an external independent consultant for the Respondent, concluded that the indenting activity and trading activity in case of the Respondent are same and should earn same margins. 2) The learned TPO has determined the arm's length rate of commission from provision of indenting services by comparing the gross indenting commission (ie 8%) to net margin earned by the Respondent from trading activity (ie 11.36%) which in itself was also a controlled transaction. Reliance is placed on the following judicial precedents wherein it has been held that controlled transactions cannot be used for comparison to benchmark international transactions: - Tecnimont ICB Private Limited (ITA No. 4608/Mum/2010 dated 17 July 2012)(Mum) (Third Member Bench) - Sabic Innovative Plastic India (P) Ltd. (ITA No. 142/Ahd/2013 dated 28 June 2013) (Ahd) - Hoganas India Private Limited (ITA No. 1463/PN/2010 dated 11 January 2013) (Pune) 3) The learned TPO has not appreciated the differences in functions performed, assets employed and risks undertaken by the Respondent with respect to indenting and trading activity. (Refer Para 8.10/ Pages 15-17 of CIT(A) order) Reliance is placed on the following judicial precedents wherein it has been held that differences in functions performed, risks 12 M/s. Dow Chemical International Pvt. Ltd. assumed and assets utilized to be considered while undertaking comparability analysis: - Mastek Limited (ITA No. 3120/Ahd/2010 dated 29 February 2012) (Ahd) - Hoganas India Private Limited (ITA No. 1463/PN/2010 dated 11 January 2013) (Pune) 4) The Respondent also bench marked its transaction of receipt of indenting commission by comparing berry ratio (ie ratio of gross profit to operating expenses) which was 290.47% in case of the Respondent as against 51.67% in the case of the comparable companies. Reliance is placed on the following judicial precedents wherein it has been held that berry ratio is one of the accepted tool under TNMM method for bench marking of international transaction: - Mitsubishi Corporation India Pvt Ltd (ITA No 5042/Del/11 dated 21.10.14) (Del) - Agilent Technologies India Pvt Ltd (ITA No 4324/Del/11 dated 08.02.2016) (Del) 10.6. We have heard the rival contentions and perused the orders of the authorities below. On perusal of the TPO’s order we find that the TPO tried to compare the margins of the assessee from trading activity and the activity of indenting commission of the assessee by allowing certain adjustments and finally was of the view that the margin from indenting commission should have been more and should have been equal to the activity of trading and since the margin at which the indenting commission earned was less as compared to the trading activity, an amount of Rs. 9,03,19,798/- was made as adjustment presuming that the assessee should have earned indenting commission @ 9.21% as against 8% earned by the assessee. The Ld. CIT(A) considering the submissions of the assessee as well as the averments of the TPO/Assessing Officer concluded that 13 M/s. Dow Chemical International Pvt. Ltd. there cannot be a comparison at all with these two activities i.e trading and indenting activities of the assessee, deleted the adjustment observing as under:
“8.16 I have considered the submissions and the explanations made by the appellant. I have also observed that the appellant proposed adjustments for the following and the learned TPO has allowed certain adjustment before comparison can be undertaken between trading and indenting: a) Interest on working capital - not allowed b) Bad debts - allowed c) Entrepreneurial risk - not allowed d) Inventory obsolescence - allowed e) Warehousing - not allowed f) Short term stress on finance - allowed g) Distribution network - allowed 8.17. Based on the submissions and explanation made by the appellant, the functional and the risk profile and the fact that adjustments have been allowed by the learned TPO, it is evident that the functional and risk profile of the trading and indenting activities carried out by the appellant are different. Further, while the learned TPO has made certain adjustments to bridge the gap between the same, I am of the view that at it would be inappropriate to compare these activities to begin with, more specifically, the gross rate at which the Appellant earns commission for indenting activities cannot be compared to the net profit it makes in the trading business. Further, it has been explained that the products traded by the appellant are different to the products on which it earns commission income from its AEs. 8.18, Separately, the Appellant explained during the course of the appellate proceedings that the learned TPO has compared two controlled transactions which defeats the very purpose of undertaking transfer pricing analysis. I am in agreement with the appellant and in light of decision in the case of Sony India ' 14 M/s. Dow Chemical International Pvt. Ltd. Pvt Ltd, Philips Software Centre Pvt. Ltd., Skoda Auto India Pvt. Ltd., I am inclined to hold that these transactions cannot be compared on two accounts, namely difference in their functional profile as well as the fact that they constitute comparison of a controlled transactions with another controlled transaction. 8.19. Thus taking an overall view of the matter and for the reasons recorded I am of the considered view that there would be no transfer pricing adjustment in adjustment in appellants case. On going through the order of the Ld. CIT(A), we do not find any infirmity in the order of the Ld. CIT(A) in deleting the TP adjustments made by the TPO. Ground raised by the Revenue is dismissed on this issue.
This appeal is filed by the assessee against the order of the Ld. CIT(A)-15 dated 14.6.2010 pertaining to Assessment Year 2005-06. 11.1. The assessee is challenging the order of the Ld. CIT(A) in confirming the action of the Assessing Officer considering the computer lease payments of Rs. 26,79,730/- made to IBM as capital expenditure.
11.2. The assessee by letter dated 22.8.2014 filed an additional evidence in the form of letter from IBM India Pvt. Ltd., to the effect that under the Term Lease Master Agreement between the assessee and the IBM India Pvt. Ltd., computers were provided on lease to the assessee by IBM. The Ld. Counsel for the assessee submits that the expenditure was held to be capital expenditure by the lower authorities. However, since the computers were taken on lease, the lease rent charges paid by the assessee are to be allowed as revenue expenditure. He further submits that since the additional evidence 15 M/s. Dow Chemical International Pvt. Ltd. produced is going to the root of the matter, the same may be admitted and restored to the file of the Assessing Officer for verification and adjudication. The Ld. Counsel for the assessee further submits that the Co-ordinate Bench of the Tribunal while dealing with the appeal for Assessment Year 2006-07 in dated 10.3.2015 the very same issue was restored to the file of the Assessing Officer with the direction to decide the issue afresh after considering the lease agreement and certificate given by IBM and any other material information.
11.3. The Ld. Departmental Representative has no serious objection in remitting the matter back to the file of the Assessing Officer for fresh examination.
11.4. We have heard the rival contentions, perused the orders of the authorities below and the Co-ordinate Bench decision for the Assessment Year 2006-07. The additional evidences filed by the assessee are admitted. We find that similar issue had been restored to the file of the Assessing Officer by the Co-ordinate Bench with the following observations:
“At the time of hearing, the Ld A.R placed strong reliance on the lease agreement and submitted that the terms of the lease agreement clearly show that the same was an “Operating lease” only. However, we notice from the orders of tax authorities that they have not examined the lease agreement in order to find out the actual nature of the lease i.e. whether it was a financial lease or an operating lease. The ld. counsel 3 submitted that the DRP has confirmed the order of the AO on the ground that the assessee was not able to explain as to what would be the treatment to the computer after the expiry of lease period. The ld. Counsel submitted that the lease agreement specifically provides that the computer would be returned back to M/s IBM. He further submitted that the assessee has also obtained a certificate to that effect from M/s IBM. Thus, in our view, the present dispute could be resolved only if a definite finding about the nature of lease is given. We have already noticed that both the authorities have failed to examine the lease agreement which, in our view, is essential. Accordingly, we are of the view that this issue requires fresh examination at the end of the AO.
16 M/s. Dow Chemical International Pvt. Ltd. Accordingly, we set aside the order of the AO and restore this issue to the file of the AO/DRP with a direction to decide the same afresh by duly considering the lease agreement, certificate given by the M/s IBM and any other information/explanations that may be furnished by the assessee”.
Following the said order, we restore this issue to the file of the Assessing Officer with a direction to decide the issue afresh by considering the lease agreement, certificate given by M/s. IBM and any other information that may be furnished by the assessee. The Assessing Officer shall give adequate opportunity of being heard to the assessee.
11.5. In the result, the appeal filed by the assessee is allowed for statistical purpose.
ITA No. 6535/M/2010 – A.Y. 2005-06
The first issue in the appeal of the Revenue is that the Ld. CIT(A) erred in deleting the addition related to computer expenses.
12.1. Both the parties agreed that the same issue has arisen in the appeal of the Revenue for the Assessment Year 2004-05 and the arguments therein applies to this year also.
12.2. We have perused the orders of the authorities below. We have decided this issue while dealing with the appeal for Assessment Year 2004-05 at para 8 to 8.5. Since the issue in this Assessment Year 2005-06 is identical, for similar reasons, the decision taken for the Assessment Year 2004-05 applies mutatis mutandis to this issue for this Assessment Year also. Thus the ground raised by the Revenue is dismissed.
17 M/s. Dow Chemical International Pvt. Ltd.
The next issue in the appeal of the Revenue is that the Ld. CIT(A) erred in deleting the addition made u/s. 40(a)(ia) of the Act. 13.1. The Assessing Officer invoking the provisions of Sec. 40(a)(ia) disallowed payments made by the assessee to contractors, commission expenses and professional fees since the assessee did not pay the TDS within time.
13.2. On appeal, the Ld. CIT(A) deleted the disallowance observing that assessee has deposited the TDS within the end of the financial year, thus it is entitled to claim deduction of the expenses.
13.3. The Ld. Departmental Representative vehemently supports the order of the Assessing Officer.
13.4. The Ld. Counsel for the assessee submits that Clause (B) of Sec. 40(a)(ia) entitles the assessee to claim deduction in respect of payments, on which tax has been deposited after the due date but before the end of the financial year. The Ld. Counsel for the assessee submits that from Annexure 8 to Form 3CD report, it can be seen that the assessee has deposited the taxes deducted with the Government Treasury before 31st March, 2005 i.e. within the financial year relevant to Assessment Year 2005-06. Therefore, he submits that no disallowance is warranted u/s. 40(a)(ia) of the Act.
13.5. We have heard both parties and perused the orders of the authorities below. The issue has been considered by the Ld. CIT(A) with reference to the submissions of the assessee and averments of the Assessing Officer in the assessment order and after perusing the Tax Audit report, the Ld. CIT(A) deleted the disallowance observing as under:
18 M/s. Dow Chemical International Pvt. Ltd. “8. The seventh ground of the appeal is that the Assessing Officer erred in disallowing following payments u/s. 40(a)(ia) of the Act. i) Payment made to contractors of Rs. 13,52,650/- ii) Commission expenses of Rs. 5,80,960 and iii) Professional fees of Rs. 61,40,720/- 8.1. In parap 8.6 of the assessment order passed u/s. 143(3) of the Act, the Assessing Officer disallowed payments on the ground that payment of TDS has been made after the due date prescribed u/s. 200(1) of the Act.
8.2. In the appellate proceedings, the Appellant submitted that: i) Clause (B) of Sec. 40(a)(ia) entitles the Appellant to claim deduction in respect of payments, on which tax has been deposited after the due date but before the end of the financial year. ii) From annexure 8 of Form 3CD, it can be seen that the appellant has deposited the taxes deducted with the Government Treasury before 31st March, 2005 i.e. within the financial year relevant to Assessment Year 2005-06. 8.3. I have considered the facts of the case and submissions of the Assessing Officer and the appellant company. The appellant has deposited the TDS within the end of the financial year and thus, it is entitled to claim deduction of the expenses. Taking into consideration the entirety of the facts of the case I am of the opinion that the Assessing Officer erred in disallowing the expenditure u/s. 40(a)(ia). Accordingly, the addition made by the Assessing Officer is hereby deleted”.
19 M/s. Dow Chemical International Pvt. Ltd. 13.6. On going through the order of the Ld. CIT(A), we do not find any infirmity in deleting the disallowance made u/s. 40(a)(Ia) of the Act, therefore we sustain the order of the Ld. CIT(A) on this issue.
The next issue is regarding Transfer Pricing Adjustment. Both the parties agreed that the same issue has arisen in the appeal of the Revenue for the Assessment Year 2004-05 and the arguments therein applies to this year also.
14.1. We have perused the orders of the authorities below. We have decided this issue while dealing with the appeal for Assessment Year 2004-05 at para 10 to 10.6 in favour of the assessee by deleting the adjustment made. Since the issue in this Assessment Year 2005- 06 is identical, for similar reasons, the decision n for the Assessment Year 2004-05 applies mutatis mutandis to this Assessment Year also. Thus, the ground raised by the Revenue is dismissed.
In the result, the appeals filed by the Revenue are dismissed and the appeal filed by the assessee is allowed for statistical purpose.
Order pronounced in the open court on 22nd July, 2016. (RAJENDRA) (C.N. PRASAD ) लेखा सद"य / ACCOUNTANT MEMBER "या"यक सद"य/JUDICIAL MEMBER मुंबई Mumbai; "दनांक Dated 22nd July, 2016 व."न.स./ Rj , Sr. PS