ACIT 2 (1), INDORE vs. M/S JILA INDUSTRIES LTD, DHAR

आदेश / O R D E R PER BHAGIRATH MAL BIYANI, A.M: This is an appeal by Revenue against the order dated 03.07.2018 passed by Ld. CIT(A)-I, Indore [“Ld. CIT(A)” for short] in Appeal No. IT-162/2016-17, arising out of the assessment-order dated 28.03.2013 passed by Ld. ITO-4(1), Indore [“Ld. AO” for short] u/s 143(3) of Income-tax Act, 1961 [“the Act” for short] for Assessment Year 2013-14.

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“1. Whether in the facts and circumstances of the case, Ld. CIT(A) has erred in deleting the addition of Rs. 1,71,32,125/- on account of commission expenses relying on the submission filed by the assessee.

1.1 Whether in the facts and circumstances of the case, Ld. CIT(A) has erred in holding that Mr. Aashik Asaria, the payee is resident of UAE and has no permanent establishment in India and payment was not made on behalf of assesse, without any verification of the claim by any enquiry or remand report.

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certain additions. Aggrieved by the order of assessment, the assessee filed appeal to Ld. CIT(A). The Ld. CIT(A) deleted additions and allowed the appeal. Being aggrieved by the order of Ld. CIT(A), the Revenue has preferred this appeal and now before us.

4.1 In this Ground, the Revenue has urged to decide whether the Ld. CIT(A) was justified in admitting the additional evidences in violation of Rule 46A of Income-tax Rules, 1962. As this Ground goes to the root of the matter, we firstly take up this and thereafter other Grounds which are on merit.

4.2 During the proceeding of first-appeal, the assessee filed an application to Ld. CIT(A) alongwith additional evidences under Rule 46A of Income-tax Rules, 1962. The assessee submitted that there was a fire in its factory as a result of which the documents were lost/damaged, stock was damaged, financial crisis occurred, the business had to be closed and there were total disruptions due to which the assessee could not file evidences before the Ld. AO during assessment-proceeding. Citing these reasons, the assessee prayed the Ld. CIT(A) to admit its application for additional evidences under Rule 46A.

4.3 The Ld. CIT(A) forwarded assessee’s application alongwith all accompanying evidences to Ld. AO vide his letter F.No. CIT(A)- I/Ind/Remand-Report/2017-18 dated 11.01.218 for comments and Remand-Report. In response thereto, the Ld. AO submitted 3

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Remand-Report bearing No. JCIT(OSD)/Ind/Remand Report/2017- 18 dated 08.05.2018.

4.4 The Ld. CIT(A) took into account the Remand-Report submitted by Ld. AO and finally admitted the assessee’s request for additional evidences vide Para No. 4 of his order, by observing as under:

“The fire broke out at the plant of the appellant. The plant remained closed and damaged the papers which requires for assessment proceedings. Therefore, there was sufficient cause for not producing the evidences which has been called by the assessing officer. Therefore, the appellant’s case is falling under rule 46A(1)(b) of Income-tax Rules. Therefore, additional evidences produced during the course of appellate proceedings have been admitted and the additional evidences forwarded to the AO for his comments. The AO submitted remand report dated 08/05/2018.” 4.5 Before us, the Ld. D/R just re-iterated the plea taken in the Ground and submitted that the Ld. CIT(A) was not justified in admitting additional evidences. Per contra, the Ld. A/R invited our attention to the findings contained in the Para No. 4 of the order of CIT(A), reproduced above, and argued that the Ld. CIT(A) has rightly admitted the additional evidences as per provisions of Rule 46A(1)(b) and hence this action of Ld. CIT(A) needs to be upheld. The Ld. A/R also placed reliance on following decisions:

(i) CIT Vs. Jagjot Singh and Sons (2014) 41 taxmann.com 423 (Allahabad) (ii) CIT Vs. Eicher Tractors Ltd. (2007) 165 Taxmann 226 (Delhi)

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4.6 We have given a careful consideration to the material available on record and the contentions put forward by both sides. On a careful consideration of the same, we observe that the Ld. CIT(A) has sent application of assessee alongwith additional evidences produced by the assessee to the Ld. AO and invited comments from Ld. AO. In response, the Ld. AO filed a detailed Remand-Report dated 08.05.2018. This way the Ld. CIT(A) has given the fullest opportunity to the Ld. AO and the Ld. AO has also utilized the same. We have also perused the Remand-Report placed by Ld. A/R at Page No. 7 of the Paper-Book. On perusal we find that the Ld. AO has made following reporting in Para No. 5 of the Remand-Report:

“5. As regards my comments on admissibility of additional evidences, I may submit that the AO making assessment has given full opportunity of being heard, but assessee failed to make any compliance. However, in the assessment, the additions have been made on assessee’s failure to furnish documents required to justify its claim. It is claimed that due to above mentioned hardship, the assessee could not produce supporting documents and the assessee’s claim is that it was prevented by sufficient cause in not submitting the above papers at the time of assessment, which are relevant for the purpose of assessment, the same may please be considered at appellate stage by your honour, if deem fit.” A careful reading of this demonstrates that the Ld. AO has neither uttered any objection against the assessee’s application for additional evidences nor found any kind of deficiency in the same. In fact, the Ld. AO has holistically considered the inability of the assessee to submit the documents during the assessment- proceeding and left the matter to the wisdom of the Ld. CIT(A) by stating “… the same may be considered at appellate stage by 5

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your honour, if deem fit”. We have also considered Para No. 4 of the order of Ld. CIT(A) reproduced above and observe that the Ld. CIT(A) has considered the outbreak of fire and consequential disruptions as a sufficient cause and therefore admitted the additional evidences as per specific mandate of Rule 46A(1)(b). We observe that Rule 46A(1)(b) prescribes thus:

“46A(1) The appellant shall not be entitled to produce before the Deputy Commissioner (Appeals)] or, as the case may be, the Commissioner (Appeals), any evidence, whether oral or documentary, other than the evidence produced by him during the course of proceedings before the Assessing Officer, except in the following circumstances, namely :— (a) XXX (b) where the appellant was prevented by sufficient cause from producing the evidence which he was called upon to produce by the Assessing Officer.” 4.7 From the above factual aspects and the mandate of Rule 46A(1)(b), we do not find any infirmity in the action of Ld. CIT(A) in admitting the additional evidences. Therefore, we hold that the Ld. CIT(A) was justified in admitting additional evidences in terms of Rule 46(A)(1)(b). Thus, we dismiss this Ground of Revenue.

5.1 In this Ground, the issue involved is the disallowance of commission expenditure of Rs. 1,71,32,125/-. 5.2 Facts qua this issue are such that the assessee paid a commission of Rs. 1,71,32,125/- to Mr. Aashik Asaria, a resident of UAE in respect of sales made to M/s Overseas Metal Trading Co., UAE. The assessee has claimed deduction of this commission- 6

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payment as business expenditure. During assessment proceedings, the Ld. AO called for the details of commission expenditure but the assessee did not submit. Therefore, while completing assessment, the Ld. AO disallowed this commission expenditure by observing as under:

“Selling Expenses include Commission on Export Sales amounting to Rs. 1,71,32,125/-, as against last year’s such expenses relating to export sales at Rs. 14,26,636/-. The assessee was, vide detailed questionnaire issued on 19-11-2012 required to furnish details of such expenses and details of TDS made therefrom and items covered u/s 43B and also to furnish copy of TDS returns. No such details have been furnished. It could not be verified as to whether such commission payment has been subjected to TDS u/s 194H or not, and if TDS is deducted whether the same has been deposited to the Central Govt. A/c within the time allowed u/s 43B of the IT Act. In the absence of the assessee’s substantiating the genuiness of the claim of commission payment of Rs. 1,71,32,125/-, the claim is not allowed and hence it is added back to the total income of the assessee.” 5.3 The Ld. CIT(A) has, however, deleted the disallowance vide Para No. 5.2 by observing as under:

“5.2 Ground No.2: Through this ground of appeal, the appellant has challenged the addition of Rs. 1,71,32,125/- on account of commission expenses. During the year under consideration the appellant has paid the commission of Rs. 1,71,32,125/- as against Rs. 61,96,000/- paid in the previous year. The sales commission was paid to Mr. Aashik Asaria, Resident of UAE. The sale was made to M/s Overseas Metal Trading Co., UAE. The appellant furnished the copy of agreement dated 01/10/2008 with the sales agent. The AO made the addition on the ground that appellant has not deducted the TDS on the commission paid. The appellant stated that the commission has been paid to the non-resident and provision of section 40(a)(i) of The Act is not applicable. 7

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5.2.1 The appellant company is carrying business of manufacturing and trading of aluminum extrusion. The appellant company also engaged in the export. The payment of commission is worked out as per the agreement executed with Mr. Aashik Asaria, resident of UAE. The commission is paid on the basis of sales executed by the broker. The commission is directly paid to the said broker by the purchase party and appellant company is not required to issue any bills or Debit Notes for the same. The broker is foreign entity having no permanent establishment in India and income earned by the broker is not chargeable to tax in India.

5.2.2 The section 195 stated that, any person responsible for paying to a non-resident or a foreign company, any sum chargeable to tax under the Act is required to deduct tax at source at the rates in force. The appellant company is paying advertisement charges/sales promotion which are the business receipts of those companies and therefore being the entity not chargeable to tax in India, no deduction of tax is required. There is no requirement of TDS. The section 40(a)(i) of The Act is also not applicable. 5.2.3 The explanation to section 195 which has made amendment in Finance Act. 2012 shall be applicable only to the entities which are taxable in India in any manner but not to the companies which are not liable to be taxed in India. The judicial interpretation always stands that the explanation cannot overrule the main section and in this regard the specific mention in the Tribunal Order in Case of Prithvi Information Solutions Ltd. where the ITAT HYDERABAD Bench has further clarified that “Even though Explanation 2 to section 195 clarifies the position that whether or not a non-resident person has a residence or place of business or business or business connection in India or any, the Explanation cannot override the main provision of section 195 about ‘sum chargeable’ under the provisions of the Act. As defined in section 5, no income accrues or arises or deemed to accrue or arise in India on the payments made in USA by branch there. Therefore, the payments made abroad cannot be considered as income chargeable under the provisions of the Act.” Hence, in light of 8

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the above, the appellant is not liable to deduct TDS on foreign payments not chargeable to tax in India.

5.2.4 The above person to whom payments of commission made have presence in UAE. In this case the aforesaid person has no permanent establishment or business connection in India and since it is not liable to tax in India. Therefore the payment is not liable to TDS u/s 195 of The Act. Further as per the Judicial Pronouncement, the treaty with any country will always prevail over the Income Tax Act. 1. Union of India vs.Azadi Bachao Andolan {2003} 132 Taxman 373 (SC). 2. Director of Income Tax vs. New Skies Satellite BV. {2016} 68 taxmann.com 8 (Delhi). 5.2.5 Therefore, the addition made by the AO amounting to Rs.1,71,32,125/- is Deleted. Therefore, the appeal on these grounds is Allowed.” 5.4 Before us, the Ld. D/R relied upon the order of Ld. AO and argued that the disallowance was rightly made, which needs to be upheld.

5.5 Per contra, the Ld. A/R has submitted that the assessee has paid commission of Rs. 171.32 lacs as against Rs. 61.91 lacs in the immediately preceding year. According to Ld. A/R, the mention of Rs. 14.26 lacs by Ld. AO as commission-payment in the immediately preceding year is incorrect, the correct amount being Rs. 61.91 lacs. The Ld. A/R submits that having regard to the correct figures of commission-payment and the quantum of export- sales of both years, the payment made by the assessee is quite comparable and reasonable looking to the prevailing market. Regarding non-submission of evidences during assessment- proceeding, the Ld. A/R submitted that there existed sufficient 9

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cause which prevented the assessee from filing the evidences called for by Ld. AO. But subsequently during appellate proceedings, the assessee submitted all evidences to Ld. CIT(A) in terms of Rule 46A(1)(b). The Ld. A/R further submitted that the evidences filed to Ld. CIT(A) in this regard were (i) copy of the agreement with the agent, (ii) sample copies of sales-bills for which the commission was paid to agent, (iii) calculation sheet of commission, and (iv) sample copy of the purchase-contract agreed between the assessee and foreign buyer in which the name of Mr. Aashik Asaria (or Mr. Ashiq Asaria) is clearly mentioned as agent and it is also categorically mentioned that the foreign-buyer will pay commission to Mr. Ashiq Asaria from the sales proceed. The Ld. A/R also invited our attention to Page No. 49 to 55 of the Paper-Book where these evidences are placed. Regarding non-deduction of tax at source, the Ld. A/R submitted that the payee is in fact a Non-Resident and the commission payment is not chargeable to tax in India and, therefore, the requirement of TDS u/s 195 does not arise. In this regard, the Ld. A/R has also placed reliance on following decisions:

(i) DCIT Vs. M/s Sterling Ornament (P) Ltd. ITA No. 4395/Del/2014, ITAT Delhi, order dated 27.06.2018

(ii) Pr. CIT-5, Bangalore Vs. Puma Sports India Pvt. Ltd. ITA No. 223 / 2018 dated 12.03.2021, Karnataka High Court

With these submissions, the Ld. A/R argued that the Ld. CIT(A) has rightly deleted the disallowance made by Ld. AO.

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5.6 We have considered the material held on record as also the rival contentions of both sides. A perusal of the assessment-order reveals that the assessee was not able to submit the evidences in support of claim of commission-expenditure as required by Ld. AO and this prompted the Ld. AO to make disallowance. However, as noted earlier, the assessee has submitted additional evidences in the form of (i) copy of the agreement with the agent, (ii) sample copies of sales-bills, (iii) calculation sheet of commission, and (iv) sample copy of the purchase-order received from the foreign-buyer, to the Ld. CIT(A) and those evidences stand admitted in terms of Rule 46A(1)(b). We observe that the Revenue has not pointed out any deficiency in these admitted evidences. Hence from these evidences, it is amply clear that the assessee has paid commission for business expediency. Regarding non-deduction of tax at source u/s 195 by the assessee, we observe that it is a well-settled law that the requirement of TDS u/s 195 arises only if the relevant sum is chargeable to tax in India. If the sum is not chargeable to tax in India, there is no requirement of TDS at all and this proposition is also supported by the decisions quoted by Ld. A/R mentioned earlier.

5.7 At this stage we also take note of the Ground No. 1.1 wherein the Revenue has claimed that the Ld. CIT(A) has erred in holding Mr. Aashik Asaria as a resident of UAE having no permanent establishment in India and that the payment was made on behalf of assessee, without any verification of the claim by any enquiry or

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remand report. In this regard, we observe from the copy of agreement placed at Page No. 52 of the Paper-Book that Mr. Ashiq Asaria is having address of P.O. Box No. 29421, Sharjah, UAE, which indicates that he is a non-resident. Regarding payment of commission on behalf of assessee, we peruse the condition No. 8 of this Agreement which reads as under:

“Agent will be entitled to receive commission as and when sales proceeds has been received from buyer. Principal can authorize agent to collect his commission from buyer directly” We have also perused the condition No. 3 of the sample Purchase- Contract agreed between the foreign-buyer and assessee and placed at Page No. 54 of the Paper-Book, which reads as under:

“3. Others: “Buyer will pay sales commission to Mr. Ashiq Asaria as and when instructed by seller from the balance of sale proceeds. Further this contract is governed by the terms of international business practices”. These terms and conditions, which are not controverted by the Revenue, clearly demonstrate that the foreign-buyer has directly paid commission to Mr. Ashik Asaria, out of the sale proceed belonging to the assessee. Therefore, the Ground No. 1.1, which is a part of Ground No. 1, does not have any substance.

5.8 In view of the forgoing discussion, we do not find any infirmity in the order of Ld. CIT(A). Therefore we hold that the Ld. CIT(A) was justified in deleting the disallowance. Accordingly, this Ground of Revenue is also dismissed. 12

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6.1 In this Ground, the issue involved is the addition on account of increase in share capital of Rs. 75,00,000/- u/s 68.

6.2 Facts qua this issue are such that the assessee-company has raised new share capital of Rs. 75,00,000/- during the year. During the course of assessment-proceeding, the Ld. AO required the assessee to submit evidences in support of the receipt of Rs. 75,00,000/- but the assessee did not submit. Therefore, while completing assessment, the Ld. AO invoked section 68 and made an addition of Rs. 75,00,000/- by observing as under:

“As per the audited accounts, the paid up capital at the close of last year was Rs. 75,00,000/- whereas the same has been increased to Rs. 1,50,00,000/- during this year, thus, the assessee company has raised share capital by issuing fresh shares amounting to Rs. 75,00,000/-. Vide Q. No. 14 of notice u/s 142(1), the assessee was required to establish the identity, genuineness and creditworthinedss of the share applicants and also to furnish register of shares and a copy of application thereof. No such details have been produced / furnished and in such circumstances, the identity and creditworthness of the subscribers to the new shares to the extent of Rs. 75,00,000/- could not be established. Even the assessee has not stated the individual shares subscribed by the sharesholders afresh during the year in spite of various opportunities allowed as detailed above. As such the investment in shares to the extent of Rs. 75,00,000/- is treated as unexplained investment of the assessee company and as such the same is charged to income tax for the year under consideration u/s 68 of the I.T Act,1961.”

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6.3 The Ld. CIT(A) has, however, deleted this addition vide Para No. 5.1 by observing as under:

“5.1 Ground No.1: Through this ground of appeal, the appellant has challenged the addition of Rs. 75,00,000/- on account of increase in Share Capital. The appellant has received share capital of Rs. 75,00,000/- from the following persons:-

S.No. Name of the Persons Share Capital (Rs.) 1 Shri Aabhash Maheshwari 4,00,000/- S/o Shri Ramesh Mungad 2 Shri Gaurav Mungad 9,50,000/- S/o Shri Om Prakash Maheshwari 3 Smt. Madhu Maheshwari 50,000/- W/o Shri S.N. Maheshwari 4 Shri Om Prakash Maheshwari 2,00,000/- S/o Shri Chhaganlal Maheshwari 5 Smt. Sushila Mungad 50,000/- W/o Shri O.P. Maheshwari 6 Shri Vaibhav Mungad 58,50,000/- S/o Shri Om Prakash Maheshwari

The company has received share capital from its directors and family members. The appellant has received the money from the person by cheque and all the depositors are having PAN Number. The lender parties furnished the confirmations, PAN Number, Bank Pass Book and Proof of furnishing of the filing of return. The appellant furnished the following documents in support of his claim. 1. Confirmations. 2. Copy of ITR, wherever return has been filed. 3. Proof of source of income. 4. Bank name and cheque Number.

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By filing the above documents the appellant is able to establish the i. Identity of the creditors – the share applicants are income tax payers and filed the confirmations. ii. Genuineness of the transaction- the appellant has taken the share application money through banking channel. The appellant is in the receipt of share application money by cheque. iii. Creditworthness of the creditors- The persons had given the share application money to the appellant and confirmed the same. 5.1.1 From the above it is clear that the appellant has satisfied all the three conditions required for genuiness of the transaction. It is also to be mentioned that most of the credit parties are assessed to tax. The AO in the remand report dated 08/05/2018 has not commented adversely. The same view has been upheld by Hon’ble ITAT in the following cases:- i. Umesh Electricals v/s Asst. CIT (2011) 18 ITJ 635 (Trib.- Agra): (2011) 131 ITD 127 : (2011) 141 TTJ Establishment of identity and credit-worthniness proved – Assessee produced the bank account of creditor in his bank account on the same day on which loan was given – Assessee furnished the cash flow statement of creditor-Based on inquiry, AO noted that creditor was engaged in providing accommodation entries – HELD - In group cases, it has been held that there was no evidence against the creditor to prove that he was providing accommodation entiries. . . Further, mere . depost of money by the creditor on the same day, does not establish that the loan in not genuine - Assessee has proved the source of credit and also the source of source – Addition cannot be made.

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ii. Aseem Singh v/s Asst. CIT (2012) 19 ITJ 52 (Trib-Indore)

Identity and credit-worthiness proved-Assessee took loan of Rs. 1,00,000/- confirmation of creditor was filed - Lower authorities made addition u/s 68 holding that amount was deposited in cash in the bank account of lender immediately prior to date of loan – HELD - Assessee has established the identity – The party has confirmed the transaction - If AO doubted the transaction, AO should have called creditor u/s 131-Addition cannot be made. 5.1.2 Therefore, the AO is not justified in making the addition. Therefore, the addition made by the AO amounting to Rs. 75,00,000/- is Deleted. Therefore this ground of appeal on this ground is Allowed.” 6.4 Before us, the Ld. D/R relied upon the order of Ld. AO and argued that the addition was rightly made, which needs to be upheld.

6.5 Per contra, the Ld. A/R submitted that the Ld. AO has invoked section 68 of the Act and thereby made addition of Rs. 75,00,000/- for the sole reason that the assessee could not submit the details and evidences required by Ld. AO during assessment-proceeding. But subsequently during appellate proceedings, the assessee submitted all evidences to Ld. CIT(A) in terms of Rule 46A(1)(b). The Ld. A/R further submitted that the evidences filed to Ld. CIT(A) in this regard were (i) list of the persons from whom the moneys were received, their PANs, copies of their ITRs and proofs of their sources of income, wherever available, and (ii) copy of Form-2 being Return of Allotment of shares as per Companies Act, and (iii) details of bank accounts alongwith cheques through which the moneys were 16

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received. The Ld. A/R also invited our attention to Page No. 11 to 48 of the Paper-Book where these evidences are placed. According to the Ld. A/R, these details and documents are sufficient enough to establish the identity of the shareholders, genuinuess of transaction and creditworthiness of the shareholders, as required by section 68. With these submissions, the Ld. A/R argued that the Ld. CIT(A) has rightly deleted the addition of Rs. 75,00,000/- made by Ld. AO.

6.6 We have considered the material held on record as also the rival contentions of both sides. We observe that the main reason of invoking section 68 by the Ld. AO was non-filing of documents by the assessee during the assessment-proceedings. However, the assessee has submitted additional evidences in the form of (i) list of the persons from whom the moneys were received, their PANs, copies of their ITRs and proofs of their sources of income, wherever available, and (ii) copy of Form-2 being Return of Allotment of shares as per Companies Act, and (iii) details of bank accounts alongwith cheques through which the moneys were received, to the Ld. CIT(A) and those evidences stand admitted in terms of Rule 46A(1)(b). We observe that the Revenue has not pointed out any deficiency in these admitted evidences. Hence from these evidences, the essential requirements of section 68, namely the identity of persons, creditworthiness of the persons and genuiness of transactions are adequately established. Therefore, the Ld. CIT(A) has rightly deleted the addition of Rs. 75,00,000/-. Accordingly, we

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uphold the action of Ld. CIT(A) and dismiss this Ground of Revenue too.

Order pronounced as per Rule 34 of I.T.A.T. Rules 1963 on 25/02/2022.

Sd/- Sd/-

(SUCHITRA R. KAMBLE) (BHAGIRATH MAL BIYANI)

JUDICIAL MEMBER ACCOUNTANT MEMBER

Indore; �दनांक Dated : 25/01/2022

Patel/Sr. PS Copy to: Assessee/AO/Pr. CIT/ CIT (A)/ITAT (DR)/Guard file.

By order Assistant Registrar, Indore