ITO 9(2)(2), MUMBAI vs. KALYPTO RISK TECHNOLOGIES P.LTD, NAVI MUMBAI

4 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 respective counsel, if kept in juxtaposition and analyzed, the facts, in brief, are that the assessee is a private limited company, engaged in development of risk based software mainly for banking industry. The assessee along with development of software also providing annual maintenance contract (AMC), after completion of warranty period. As per the assessee, normally, the development of software and its implementation services are like a project, which covers a period of more than one year and the accounting of the Revenue are therefore, split into more than one accounting period. During the relevant assessment year, there were ongoing projects and also new projects were signed as per the terms and conditions of the agreement and further raising the invoices. During the relevant period, the assessee made the additions to the intangible assets being the software development cost on a systematic basis provided for amortization of the same, which was regularly followed by the assessee and the department accepted the same. However, the ld. Assessing Officer applied the amortization over a period of ten years ignoring the rates of depreciation, provided under the Income Tax Act, 1961, u/s 32, Rule 5(appendix -1 part-B). The ld. Assessing Officer asked the assessee to justify the claimed expenses under the head depreciation against intangible assets capitalized in software development. The assessee explained his position, however, the same was declined and the impugned addition was made.

5 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 2.2. On appeal before the ld. Commissioner of Income Tax (Appeals), the provision of the Act, factual matrix and accounting standard (AS 26), issued by ICAI, with respect to accounting and amortization period were considered. For ready reference, we are reproducing hereunder:- “The following are not components of the cost of an internally generated intangible asset. a. Selling, administrative and other general overhead expenditure unless this expenditure can be directly attributed to making the asset ready for use. b. Clearly identified inefficiencies and initial operating losses incurred before an asset achieves planes performance; and c. Expenditure on training the staff to operate the asset. Past Expenses not to be Recognised as an Asset 58. Expenditure on an intangible item that was initially recognised as an expense by a reporting enterprise in previous annual financial statements or interim financial reports should not be recognised as part of the cost of an intangible asset at a later date.

Subsequent Expenditure 59. Subsequent expenditure on an intangible asset after its purchase or its completion should be recognised as an expense when it is incurred unless:

(a) it is probable that the expenditure will enable the asset to generate future economic benefits in excess of its originally assessed standard of performance; and (b) the expenditure can be measured and attributed to the asset reliably.

6 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 If these conditions are met, the subsequent expenditure should be added to the cost of the intangible asset. Amortisation period 63. The depreciable amount of an intangible asset should be allocated on a systematic basis over the best estimate of its useful life. There is a rebuttable presumption that the useful life of an intangible asset will not exceed ten years from the date when the asset is available for use. Amortisation should commence when the asset is available for use.

(a) the expected usage of the asset by the enterprise and whether the asset could be efficiently managed by another management team; (b) typical product life cycles for the asset and public information on estimates of useful lives of similar types of assets that are used in a similar way; (c) technical, technological or other types of obsolescence; (d) the stability of the industry in which the asset operates and changes in the market demand for the products or services output from the asset; (e) expected actions by competitors or potential competitors; (f) the level of maintenance expenditure required to obtain the expected future economic benefits from the asset and the company's ability and intent to reach such a level; (g) the period of control over the asset and legal or similar limits on the use of the asset, such as the expiry dates of related leases; and 7 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 (h) whether the useful life of the asset is dependent on the useful life of other assets of the enterprise.

Know-how, patents, copyrights, trademarks, licences, franchises or any other business or commercial rights of similar nature Notes: 1. "Buildings" include roads, bridges, culverts, wells and tubewells. 2. A building shall be deemed to be a building used mainly for residential purposes, if the built up floor area thereof used for residential purposes is not less than sixty-six and two-third per cent of its total built-up floor area and shall include any such building in the factory premises.

4. Water treatment system includes system for desalination, demineralisation and purification of water.

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5. Electrical fittings" include electrical wiring, switches, sockets, other fittings and fans, etc.

2.3. If this issue is analyzed with respect to principle of consistency, it is also noted that for A.Y. 2007-08, no addition was made by the same Assessing Officer. Further, for A.Y. 2008-09, addition was made but the same was deleted by the ld. Commissioner of Income Tax (Appeals). Identical is the situation for A.Y. 2009-10 and for A.Y. 2010-11, no addition was made by the Assessing Officer. In view of these facts, the 9 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 ld. Assessing Officer is expected to follow the principle of consistency unless and until contrary material/facts are brought on record. On the issue of consistency, we are supported by following decisions:- i. Parshuram Pottery Works Ltd. vs ITO 106 ITR 1 (SC) ii. Security Printers 264 ITR 276(Del.) iii. CIT vs Neo Polypack Pvt. Ltd. 245 ITR 492 (Del.) iv. CWT vs Allied Finance Pvt. Ltd. 289 ITR 318 (Del.) v. Berger Paints India Ltd. vs CIT 266 ITR 99 (SC) vi. DCIT vs United Vanaspati (275 ITR 124) (AT)(Chandigarh ITAT) vii. Union of India vs Kumudini N. Dalal 249 ITR 219 (SC) viii. Union of India vs Satish Pannalal Shah 249 ITR 221 ix. B.F.Varghese vs State of Kerala 72 ITR 726 (Ker.) x. CIT vs Narendra Doshi 254 ITR 606 (SC) xi. CIT vs Shivsagar Estate 257 ITR 59 (SC) xii. Pradip Ramanlal Seth vs UOI 204 ITR 866 (Guj.) xiii. Radhaswamy Satsang vs CIT 193 ITR 321 (SC) xiv. Aggarwal warehousing & Leasing Ltd. 257 ITR 235 (MP)

The sum and substance of the aforesaid judicial pronouncements is that on the basis of principle of judicial discipline, consistency has to be followed and once in a particular year, if any view is taken, in the absence of any contrary material, no contrary view is to be taken as finality to the litigation is also a principle which has to be followed.

10 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 Before us, no contrary facts or any adverse material was brought on record by the Revenue, therefore, we find no infirmity in the finding/conclusion of the ld. First Appellate Authority. We affirm his view being uncontroverted on fact.

2.4. Thus, totality of facts, clearly indicates that the assessee is a software development company and the cost of the development of the software is an intangible asset and the product license are IPR’s. In view of the provision of the Act and AS-26 and further the fact that the cost of development of the software is an intangible asset and the IPR’s is the product, license is not in dispute, therefore, we find no infirmity in the conclusion drawn by the ld. Commissioner of Income Tax (Appeals) to make the impugned addition. We affirm the stand of the ld. Commissioner of Income Tax (Appeals).

3. The next ground pertains to addition made on account of sales of dollar 2,52,000/- (1,00,22,040/-) to M/s 3i Infotech being suppressed sales as per agreement with 3i Infotech.

3.1. The crux of argument advanced by ld. DR is in support to the assessment order by inviting out attention to the finding contained in the order of the ld. Assessing Officer as well as of the ld. Commissioner of Income Tax (Appeals). On the other hand, the ld. counsel for the assessee drew our attention to page 62 of the paper book, containing agreement with the assessee dated 29/10/2010, page 72, page 74 with 11 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 respect to terms of payment by explaining that the assessee billed license fee at 50% and the total fee is $ 2,55,000, the 50% of which comes to $ 1,20,500. The front end commission was $ 90,000/-, thus, the 50% of which comes to $ 45,000. The warranty fee for three years was explained to be $ 66,000, the 50% of which was billed at $ 33,000. The gross billing was thus claimed to be $ 2,39,000 and thus the net comes to $1,60,000. Our attention was invited to page 76 of the paper book (invoice), which is identical i.e. $ 1,60,000. Our attention was further invited to page 75 containing the ledger account of the party. It was also explained that prior to issue of Circular No. 7 of 2009 dated 22/10/2009 income was not taxable in India (page 253 of the paper book) and further Circular NO.786 dated 07/02/2000 (page 254 of the paper book). It was explained that the case of the assessee is prior to circular, thus, the circular has to be applied prospectively for which reliance was placed upon the jurisdictional High Court Basf(India) Ltd. & Ors. vs Commissioner (280 ITR 136) (Bom.) and also the decision of the Tribunal in Sanjiv Gupta vs Dy. CIT (ITA No.587 (LKW)/2010). The clarifications were called by the Bench with respect to front end commissions paid to the foreign agent. The ld. Counsel for the assessee made statement before the Bench that the pith and substance of the agreement is to appoint 3I infotech,Dubai as the foreign agent of the assessee for procuring order from the Skype Bank and for which the said foreign agent is paid the front end commission for securing the export order of the software for 12 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 the assessee company, realize the payments from the ultimate user of the software i.e. Skype Bank and to remit the same to the assessee company in India. Further statement was also made by the ld counsel for the assessee that the said 3I Infotech, Dubai has not rendered any part of the services in or from India and all the services for generating export order in favour of the assessee were rendered from abroad. It was also stated before the Bench that this is the only agreement with the 3I Infotech , Dubai entered into by the assessee company and there is no other agreement entered into by the assessee with 3I Infotech, Dubai with respect to this transaction of banking software been supplied by the assessee to Skype Bank, Nigeria. The ld counsel submitted that 3I Infotech , Dubai has been granted non-exclusive license by the assessee company , of which the assessee company is the owner of the said proprietary software . The said 3I Infotech has sub- licensed the said proprietary software to Skype Bank, Nigeria on the terms and conditions set forth in the agreement. The ld AR relied upon the decision of Hon’ble Madras High Court in the case of CIT v. Farida Leather Company in Tax Case Appeal No. 484 of 2015 , judgment dated 20-01-2016. The ld counsel made statement that the foreign agent rendered all services outside India and no part of services are rendered in or from India and as per the agreement the pith and substance of the agreement was to secure export orders of the software in favour of the assessee for which front end commission is paid to the foreign agent .It is stated before us by the ld counsel for 13 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 the assessee that no such technical services, experience , expertise , technical knowhow, or technical knowledge was provided by 3I Infotech, Dubai .The 3I Infotech merely sourced the prospective buyers for effecting sales of the software of the assessee. On being asked by the Bench,the Ld DR did not controvert the statement and submissions made by the ld counsel for the assessee.

3.2. We have considered the rival submissions and perused the material available on record. If the observation made in the assessment order, leading to addition made to the total income, conclusion drawn in the impugned order, material available on record, assertions made by the ld. respective counsel, if kept in juxtaposition and analyzed, we find that the Assessing Officer also considered the terms of the contract but we find that as per the working of the contract value, the assessee only invoiced only $ 1,60,000 against the total contract of $ 4,12,000 but the ld. Assessing Officer added the balance income of $ 2,52,000 as unaccounted sale at the rate 39.77 per USD making addition of Rs. 1,00,22,040. We find that the ld. Commissioner of Income Tax (Appeals) justifiably considered the agreement specially the terms and conditions as has been considered in para 4.2 of the impugned order and then reached to conclusion. The working mentioned in para 4.2 is exactly in terms of the agreement, wherein, no contradiction was pointed out by the department. Neither the ld. Commissioner of Income Tax (Appeals) found

14 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 any suppression of sale nor anything was pointed before us. Even otherwise, nothing was brought on record by the Revenue evidencing that the project was completed during the year itself, thus, we affirm the stand of the ld. Commissioner of Income Tax (Appeals).This matter was kept for clarification by the Bench with respect to the front end commissions and as per the facts as emerging from the records, orders of the authorities below and statements and submissions as made by both the counsels, we are of considered view that the front end commission as are paid by the assessee company to M/s 3I Infotech, Dubai , the pith and substance of the agreement of the assessee with the foreign agent M/s 3I Infotech, Dubai is for arranging export order of software in favour of the assessee company and since it could not be brought on record by the Revenue that services were rendered from or in India by the said foreign agent i.e. 3I Infotech nor it could be brought on record that any technical services or technical knowhow or technical expertise, experience or expertise is provided by the 3I Infotech, Dubai and also the front commission pertains to the period prior to the new circular no. 7/2009 dated 22.10.2009, we hold that there was no liability on the part of the assessee to deduct tax at source on the said payment u/s 195 of the Act and the AO erred in invoking the provisions of Section 40(a) of the Act read with Section 195 of the Act. We confirm the orders of the CIT(A). We order accordingly.

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4.1. We have considered the rival submissions and perused the material available on record. The stand of the Revenue is that the assessee suppressed the sales by analyzing the agreement with M/s Mashreq Bank, dated 27/03/2008 and further analyze the payment terms contained in schedule III and made the addition. We note that the ld. Commissioner of Income Tax (Appeals) justifiably examined the documentary evidence filed by the assessee (Para 5.2 of the impugned order), terms of the agreements, and found that 50% of the payment were to be received on implementation. The contract was signed on 27/03/2008 and up to 16 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 31/03/2008, there was no implementation of work rather the work started on 01/04/2008 for which invoice for USD 70000 was raised which is 50% of USD 1,40,000. It is also noted that in case of product, License Company and accounting of the Revenue is based on percentage completion of work method. We find no suppression of sale as has been alleged by the Revenue. We have also perused and analyzed the agreement entered into between the parties and found that practically no work was commenced in the month of March, thus, no addition was warranted. We affirm the stand of the ld. Commissioner of Income Tax (Appeals).

5.1. We have considered the rival submissions and perused the material available on record. We have also perused the agreement along with the terms of contract as per which 50% of the license fee and 50% of the implementation was to be received as advance during F.Y. 2006-07. The assessee raised the 50% of the balance amount of implementation during F.Y. 2008-09 as the project was completed during that year only. There was merger bank with HDFC bank. During the F.Y. 2007-08, the bank requested

17 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 customization work. The assessee raised the bill as per the terms of the contract but the recognition of the Revenue in service sector depends on nature of agreement and nothing has been brought on record to suggest that, right, interest and title passed on the customer during the year itself. There is no question of suppression of sale as has been alleged. We affirm the stand of the ld. Commissioner of Income Tax (Appeals).

6. The next ground pertains to addition of Rs.19,00,044/- ($ 48200) on account of M/s Ducont FZ-LLC, being unaccounted sales as per agreement with M/s Duncont FZ- LLC. The crux of argument on behalf of the Revenue is identical to the ground raised by defending the addition made by the ld. Assessing Officer. On the other hand, the ld. counsel for the assessee, contended that this ground is similar to ground no.2.

6.1. We have considered the rival submissions and perused the material available on record. We find that identically we have deliberated upon this issue while dealing with ground no. 2 and find that the details of payment has been reproduced in para 7.2 and the reasoning of the ld. Assessing Officer while making the addition in para 7.1 of the impugned order. The detailed reasoning has been considered in para 7.2 along with the circular no. 7 of 2009 dated 22/10/2009 withdrawing all circulars and find that the ld. Assessing Officer erroneously made addition of 100% of front end commission of $ 48200, whereas, the invoice was in fact

18 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 raised on only of 40% of the contract value. The circular are to be applied prospectively unless and until specifically mentioned to be applicable retrospectively. We affirm the stand of the ld. Commissioner of Income Tax (Appeals).

7. The next ground pertains to deleting the addition made on account of disallowance of commission expenses. The crux of argument on behalf of the Revenue is identical to the ground raised by contending that while grating relief to the assessee, the ld. Commissioner of Income Tax (Appeals) ignored Circular No.7/2009 dated 22/10/2009. On the other hand, the ld. counsel for the assessee, defended the conclusion arrived at in the impugned order by placing reliance upon the decision in 201 CTR (Bom.) 196 by inviting our attention to page 253 to 257 of the paper book.

7.1. We have considered the rival submissions and perused the material available on record. Before the ld. Commissioner of Income Tax (Appeals), the stand of the assessee was that the alleged circular no.7, dated 22/10/2009 is not applicable to the facts of the case as the same is effective prospectively. We note that the ld. Assessing Officer applied Circular No. 7 of 2009 to the transaction of the assessee prior to F.Y. 2007-08 when the circular was not in force as has been deliberated upon in Sanjiv Gupta vs DCIT b y the Lucknow Bench of the Tribunal (ITA No.587/LKW/2007), order dated 07/01/2011. The ratio laid down by Hon’ble jurisdictional High Court in Basf(India) Ltd.

19 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 & Ors. vs Commissioner (2006) 280 ITR 136 (Bom.), thus, we affirm the stand of the ld. Commissioner of Income Tax (Appeals). We find that identically we have deliberated upon this issue while dealing with ground no. 2 and 5 with respect to front end commission and the same decision shall apply to the front end commission of Rs.62,83,660 paid by the assessee to 3i Infotech, Dubai and Rs.19,00,044/- paid by the assessee to M/s Ducont FZ-LLC in the instant ground of appeal

8. The last ground raised by the assessee pertains to applicability of section 145(1) and 145(3) in rejecting the books of accounts by the Assessing Officer. The crux of the argument on behalf of the Revenue is identical to the ground raised. On the other hand, the ld. counsel for the assessee contended that the assessee followed accounting standard, AS-26 and there is no adverse comment by the auditor, therefore, the books of account were rejected by the Assessing Officer.

8.1. We have considered the rival submissions and perused the material available on record. The books of accounts were rejected by the ld. Assessing Officer on the plea that accounting standard were not complied with by the assessee. However, we note that the books of accounts were audited by M/s Delloitte Haskins, one of the big audit firms, who have not commented anything adverse/deviation in their audit report, thus, we find no infirmity in the conclusion of the 20 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 ld. Commissioner of Income Tax (Appeals). We affirm the same.

Finally, we find no merit in the appeal of the Revenue, consequently, dismissed.

9.1. The crux of argument advanced on behalf of the assessee is that the assessee had been consistently capitalizing certain expenses on reasonable basis for business software development with respect to employees cost (engaged in software development), occupying rental premises (for software development and depreciation on fixed assets of the premises used by the employees (located in the premises). It was explained that from A.Y. 2007-08 and till date, no disturbance to the claim of the assessee was made and the Assessing Officer accepted for A.Y. 2007-08, 2008-09 and merely for A.Y. 2009-10, he says other administrative cost also to be allocated. It was contended that no adjustment was made in other years. Our attention was invited to accountant standard AS-26 (Page 446 of the paper book) and further page

21 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 464( point 9). On the other hand, the ld. DR defended the addition made by the ld. Assessing Officer.

9.2. We have considered the rival submissions and perused the material available on record. Without going into much deliberation, it has not been disputed by the ld. DR that for earlier assessment year, the Assessing Officer accepted the claim of the assessee on identical fact, thus, on the issue of consistency, as discussed in earlier para of this order, the assessee is having a merit in its contention because in the absence of contrary facts/adverse material, the department is expected to follow the consistency. Even otherwise, as para 54 (Page 446) with respect to AS-26, the following are not components of the cost of an internally generated intangible asset. a. Selling, administrative and other general overhead expenditure unless this expenditure can be directly attributed to making the asset ready for use. b. Clearly identified inefficiencies and initial operating losses incurred before an asset achieves planes performance; and c. Expenditure on training the staff to operate the asset.

As per clause 9 of AS-26 (page 464 of the paper book), the following are not components of the cost of internally generated software:-

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(a) Selling, administration and other general overhead expenditure unless this expenditure can be directly attributable to the development of the software; (b) Clearly identified inefficiencies and initial operating losses incurred before software achieves the planned performances; and (c) Expenditure on training the staff to use the internally generated software.

9.3. In view of the above, we note that the ld. Assessing Officer has not pointed out any infirmity in the explanation of the assessee. The totality of facts, clearly indicates merits in the contention of the assessee and as canvassed by the assessee, the ld. Assessing Officer made the addition to the cost of treating the proportionate value of incidental expenses ignoring the standard practices adopted by the assessee. In view of the explanation of the assessee, we allow this ground and more specifically when for earlier assessment year, the department had been accepting the claim of the assessee and in the impugned year, no contrary facts were brought on record.

10.1. The crux of argument on behalf of the assessee is identical to ground no. 1 of the appeal of the Revenue for A. Y. 2008-09. The ld. DR consented that this ground is identical to the ground in the appeal of the Revenue.

10.2. We have considered the rival submissions and perused the material available on record. An elaborate discussion has been made by us in earlier para of this order while deciding identical ground (ground no.1) in the appeal of the Revenue for. A.Y. 2008-09, therefore, on the same reasoning, we allow the ground of the assessee.

11.1. So far as the issue of suppression of sale is concerned, we have deliberated upon, identically, on the issue while discussing ground no. 2 for A.Y. 2008-09 in the appeal of the Revenue, wherein, we find that there was no suppression of sale by the assessee as was alleged by the Assessing Officer, therefore, on the same reasoning, we allow this ground of the assessee.

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12.1. The crux of argument on behalf of the assessee is that this ground is identical to ground no. 6 for A.Y. 2008-09. The ld. DR did not object to the assertion of the assessee.

12.2. We have made an elaborate discussion in earlier para of this order, while deciding the appeal of the Revenue for A.Y. 2008-09, having discussed Circular No.7 of 2009 dated 22/10/2009, which was held to be not applicable to the facts of the case and further holding that it is applicable prospectively, thus, this ground of the assessee is also allowed.

13.1. We have considered the rival submissions and perused the material available on record. We note that in para 8 of the assessment order, the ld. Assessing Officer has 25 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 mentioned the auditor report (clause 27) (b)(iii) with respect to details of payment and tax deducted at source as is explained in the table provided in para 8 of the assessment. The ld. counsel for the assessee, explained that there was typographical error in writing the due date of remittance to the government. We have perused the record and find merit in the contention of the AR because instead of 07th February of 07th March, 2000, it was on 07th February and 07 March, 2009, thus, since there is no loss to the Revenue. The claim of the assessee is further fortified by page 42 of the paper book. Thus, this ground of the assessee is allowed as TDS amounting to Rs.453 was remitted to the government account/treasury after end of the financial year.

The appeal of the assessee is, therefore, allowed.

26 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013 15.1. The ld. DR advanced arguments which is identical to the ground raised, whereas, the ld. counsel for the assessee contended that this issue is similar to ground no. 1, raised by the Revenue, for A. Y. 2008-09. This was not controverted by the ld. DR being factually correct.

15.2. We have considered the rival submissions and perused the material available on record. We find that while deliberating upon ground no.1 for A.Y. 2008-09 in the appeal of the Revenue, we have made an elaborate discussion on this issue, therefore, on the same reasoning, we find no merit in the contention of the Department, therefore, affirm the stand of the ld. Commissioner of Income Tax (Appeals), the appeal of the Revenue, consequently, dismissed.

Finally, the appeals of the Revenue are dismissed and that of the assessee is allowed.

This order was pronounced in the open court on 18/05/2016 Sd/- Sd/- (Ramit Kochar) (Joginder Singh) लेखा सद�य / ACCOUNTANT MEMBER �या�यक सद�य /JUDICIAL MEMBER मुंबई Mumbai; �दनांक Dated : 18/05/2016 f{x~{tÜ? P.S/.�न.स. आदेश क� ��त�ल�प अ�े�षत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��यथ� / The Respondent. 3. आयकर आयु�त(अपील) / The CIT, Mumbai. 4. आयकर आयु�त / CIT(A)- , Mumbai

27 M/s Kalypto Risk Technologies Pvt. Ltd. & 2295/Mum/2013