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Income Tax Appellate Tribunal, “C” BENCH, AHMEDABAD
Before: SHRI T.R. SENTHIL KUMAR & SHRI NARENDRA PRASAD SINHA
PER SHRINARENDRA PRASAD SINHA, AM:
The present appeal is filed by the assessee against the order of the Commissioner of Income Tax (Appeals)-2, Vadodara, (in short ‘the CIT(A)’) dated 08.03.2018 for the Assessment Year 2014-15. The brief facts of the case are that the assessee had filed its return of income for A.Y. 2014-15 on 29.11.2014 declaring total income of Rs.93,14,45,622/-. The assessment was completed u/s. 143(3) of the Income Tax Act, 1961
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(hereinafter referred as ‘the Act’) on 30.11.2016 at total income of Rs.1,00,59,92,332/-. The AO had made certain additions in the course of assessment which were contested before the CIT(A) and which has been decided vide the impugned order. Aggrieved with the order of the CIT(A), the assesse has filed the present appeal.
It has been informed by the assesse vide letter dated 10th 2. April, 2024 that Piramal Finance Ltd. (PFL) had merged into erstwhile Piramal Capital & Housing Finance Ltd. w.e.f. 31.03.2018 by order of the NCLT, Mumbai dated 06th April, 2018. Thereafter, Piramal Capital & Housing Finance Ltd. had merged into Dewan Housing Finance Corporation Ltd. w.e.f. September 30, 2021, which was subsequently renamed as Piramal Capital & Housing Finance Ltd. having PAN No.AAACD1977A. The original Form No. 36 was filed in this case on 11.05.2018 by Piramal Finance Pvt. Ltd. As the said entity has finally merged with Piramal Capital & Housing Finance Ltd., a revised Form No.36 was filed by this company, which is the ultimate successor to PFL, in the course of the appeal proceeding in order to complete the technical compliance.
The assessee has taken following grounds of appeal:
GROUND I ADDITION OF INCOME AMOUNTING TO RA 14,80,285/- 1. On the facts and circumstances of the case and in law, the CTT(A) erred in upholding the action of the AO of adding a sum of Rs. 14,00,285) alleged to be received me Urbanize
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Developers India Pvt. Lad, merely on the basis of mismatch in Form 26AS.
The Appellant prays that the addition amounting to Rs. 14,00,285/- which is never received by the Appellant be deleted
GROUND II: ACTING BEYOND THE POWERS VESTED US 251 OF THE ACT:
1 On the facts and circumstances of the case and in law, the CIT(A) erred in setting aside the issue to the AO with the direction to make inquiries in respect of alleged receipt of an income of Rs.1,35,694/- from Vijaya Bank beyond the powers vested in him u/s 251 of the Act
2 He further failed to appreciate and ought to have held that no addition can be made merely on the basis of mismatch in Form 26AS and no further inquiry is called for.
3 The Appellant prays that it be held that the alleged income of Rs. 1,35,694/- from Vijaya Bank which is neither accrued nor received by the Appellant cannot be added to its income.
GROUND III: PROPORTIONATE DISALLOWANCE OF DEDUCTION CLAIMED UNDER SECTION 35AC OF THE ACT AMOUNTING TO Rs.2,36,08,173/-
On the facts and circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO of denying the deduction u/s 35AC of the Act on the alleged ground that the amount contributed to the eligible institution is spent for non-eligible projects.
The Appellant prays that the proportionate disallowance of deduction claimed u/s 35AC of the Act be deleted.
WITHOUT PREJUDICE TO GROUND III,
GROUND IV: DENIAL OF DEDUCTION U/S 80G OF THE ACT AMOUNTING TO RS 2,36,08,173/-:
1 On the facts and circumstances of the case and in law, the CIT(A) after disallowing the deduction u/s 35AC of the Act erred in denying the otherwise eligible deduction u/s 80G of the Act.
2 The Appellant prays that the deduction u/s 80G of the Act amounting to Rs.2,36,08,173/-be allowed
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GROUND V: DISALLOWANCE OF GUARANTEE COMMISSION AMOUNTING TO Rs.3,66,97,553/- PAID TO PIRAMAL ENTERPRISES LTD ("PEL")
On the facts and circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO of disallowing Rs. 3,66,97,553/, being 50% of the Guarantee Commission paid to PEL, by holding the same to be excessive as compared to the fair market value which was not disputed by the AO, without providing an opportunity to the assessee as required u/s 251(2) of the Act
He further erred in not appreciating that the expense was incurred wholly and exclusively for the purpose of business and therefore allowable u/s 37(1) of the Act and has been so allowed in the earlier year.
The Appellant prays that the disallowance of 50% of the guarantee commission paid be deleted
GROUND VI GRANT OF SHORT CREDIT OF TDS TO THE EXTENT OF RS.1,57,78.615-:
1 On the facts and circumstances of the case and in law, the AO erred in granting TDS credit of Rs. 12,98,78,591). as against Rs.14,56,57,208/, thereby granting a short credit to the of Rs. 1,57,78,615/-
2 The Appellant prays that the AO be directed to grant full credit of TDS as claimed by the Appellant and as also reflected in Form 26AS.
GROUND VII: LEVY OF INTEREST U/S 234A OF THE ACT:
1 On the facts and circumstances of the case and in law, the CIT(A) erred in upholding the levy of interest u/s 234A of the Act amounting to Rs.89,164/-
2 The Appellant prays that the interest u/s 234A of the Act amounting to Rs.89,164
Ground No.-1&2: Addition based on Form No. 26AS
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The first two grounds taken by the assessee are in respect of addition of Rs.14,00,285/- made on the basis of Form No.26AS. Shri RonakDoshi, ld. AR of the assessee explained that certain difference was found between the amount received and the TDS credit as per 26AS statement of the assessee and the amount as appearing in the books of account. As this difference was not reconciled in the course of assessment, the AO had made addition of Rs.1,84,17,486/- in respect of 4 parties as under: i. Urbanize Developers India Pvt. Ltd. 14,00,285/- ii. True Value Homes (I) Pvt. Ltd. 881,507/- iii. Vijaya Bank 135,694/- iv. True Value Homes (I) Pvt. Ltd. 16,000,000/-
The ld. CIT(A) had confirmed the addition in respect of difference of Rs.14,00,285/- appearing in the case of Urbanize Developers India Pvt. Ltd. As regarding difference of Rs.1,35,694/- in case of Vijaya Bank, the CIT(A) had directed the AO to make enquiry from the bank and thereafter decide the matter. The assessee has grievance against the decision of CIT(A) in respect of difference appearing in the name of these two parties only and the decision of the CIT(A) in respect of other two parties has not been contested.
The ld. AR submitted that no addition could have been made on the basis of Form No.26AS. He explained that a copy of ledger account of Urbanize Developers India Pvt. Ltd. as appearing in the books of the assessee was filed before the AO and, therefore, the AO was not correct in disregarding the
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evidence filed by the assessee and in making the addition on the basis of 26AS statement. The ld. AR relied upon the following decisions in support of the proposition that no addition could have been made on the basis of difference in payment received as per form 26AS and the books of accounts.
i. PCIT v. MBC Infra Space (P.) Ltd [2023] 153 taxmann.com 108 (Guj. HC) ii. Seal For Life India (P.) Ltd. v. DCIT [2018] 173 ITD 229 (Ahm. Trib) iii. P.K. Rajasekar v. ITO [2016] 161 ITD 189 (Chen. Trib.) iv. M/s. Nozaki Finance & Investment Private Ltd. v. DCIT (ITA No. 6166/Mum/2012) (Mum. Trib.) v. TUV India (P.) Ltd. v. DCIT [2019] 110 taxmann.com 175 (Mum. Trib.) vi. Kroner Investment v. DCIT (ITA No. 5125/M/2013) (Mum. Trib.)
Per contra, the ld. CIT-DR submitted that the assessee had merely filed a copy of the ledger account of Urbanize Developers India Pvt. Ltd as appearing in its books of account which was not confirmed by the other party. Therefore, the AO was correct in making the addition in respect of this difference as the same was not reconciled. As regarding difference in the case of Vijaya Bank, the ld. DR submitted that the direction of the ld. CIT(A) to verify the transaction was proper.
We have carefully considered the rival submissions and the facts of the case. There is no dispute to the fact that there was difference appearing in the accounts of the assessee vis-à- vis amount of transaction as per 26AS statement in the case of
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Urbanize Developers India Pvt. Ltd. As per 26AS statement, the total receipt from Urbanize Developers India Pvt. Ltd. was Rs.13,55,39,687/- on which TDS of Rs.1,35,57,968/- was deducted. In the return of income, the assessee had claimed credit for TDS of Rs.1,34,14,940/- only and the credit for balance TDS of Rs.1,40,028/- was not claimed and carried forward in the return and corresponding income of Rs.14,00,285/- was also not booked. A copy of the ledger account on Urbanize Developers India Pvt. Ltd. as appearing in the books of accounts of the assesse has been filed from which it is seen that there was opening balance of Rs.1,52,43,836/- and there were regular debit and credit transactions during the year. Further, the account of Urbanize Developers India Pvt. Ltd. was squared off during the year and no balance was carried forward to the next year. Once, the difference in transactions with Urbanize developers India Pvt. Ltd. was pointed out to the assessee by the AO, the onus was squarely on the assessee to reconcile this difference.
The assessee has relied upon the decision of Hon’ble Gujarat High Court in case of MBC Infra Space (P.) Ltd. (supra). In that case, the assessee had claimed that there was double deduction of TDS on the same project on certain bills and the claim of the assessee was not verified by the AO. The addition in that case was deleted after verification of bank account and contract amount received by the assessee on the basis of running bills which was upheld by the Hon’ble High Court. In the present case, no such verification has been carried
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out, neither the assessee has explained the reason for the difference. In the case of Seal For Life India (P.) Ltd.(supra), the assessee had produced reasonable evidence establishing that a particular quantum of interest income was received in his hands and no fault was found with such evidence. In the present case, no such evidence has been brought on record. The assessee has not filed even the confirmed copy of ledger account form the opposite party. In the case of P. K. Rajasekar (supra), the matter was remitted back to the AO to examine the claim of the assessee that the difference in 26AS and accounts of the assessee was due to wrong entry and wrong credit. In the case of M/s. Nozaki Finance & Investment Pvt. Ltd. (supra), the assessee had denied the amount as reported in AIR and it was held that once the assessee has objected to the amount reported in AIR, the AO was duty bound to make further enquiries. In the present case, the assessee has not denied the transaction and the TDS as appearing in 26AS statement. Thus facts of all these cases and the other cases as relied upon by the assessee are found to be different.
It is apparent from the facts as discussed above that the assessee had not denied the quantum of transaction and the TDS of Urbanize Developers India Pvt. Ltd. as reported in Form No. 26AS, rather the difference of TDS of Rs.1,40,028/- was carried forward in the return. Under the circumstances, the assessee was duty bound to reconcile the difference in the quantum of transaction as per 26AS and as appearing in the books of accounts. The assessee has also not filed any confirmation from
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Urbanize Developers India Pvt. Ltd. that ledger account appearing in its own account which was filed before the AO, was correct. The ledger account as appearing in the books of the assesse is a self-serving document and it does not explain the difference in transaction as noted in the case of Urbanize Developers India Pvt. Ltd. On the other hand, the AO has not made any enquiry from Urbanize Developers India Pvt. Ltd. on the basis of ledger account as filed by the assessee. The matter is, therefore, set aside to the file of the AO to re-examine the matter once again by making necessary enquiry from Urbanize Developers India Pvt. Ltd. The assessee may also be allowed another opportunity to reconcile the difference in respect of Urbanize Developers India Pvt. Ltd. and the AO may decide the matter after making a proper enquiry as indicated above. The ground is allowed for statistical purpose.
As regard to Ground No.2, we do not find anything wrong with the direction of the CIT(A) to make enquiry from Vijaya Bank and re-decide the matter in respect of difference of Rs.1,35,694/- as appearing in 26AS. Any mismatch between the accounts of the assessee and Form No.26AS has to be properly explained and enquired into. A direction to make specific enquiry from the bank and to re-decide the matter does not tantamount to setting aside the order of the AO. In view of discussions in respect of Ground No.1 as above, the direction of the CIT(A) is held as proper and Ground No.2 is dismissed.
Ground No.3- Proportionate disallowance u/s.35AC of the Act
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The assessee has paid a sum of Rs.11,78,12,000/- to Health Management and Research Institute, Hyderabad (HMRI) which is an eligible institute for the purpose of deduction u/s. 35AC of the Act. The claim of the assessee was examined by the AO and it was found that contribution of the assessee to HMRI had gone into its corpus. Further, HMRI had spent Rs.21,36,25,000/- on six eligible projects and an amount of Rs.5,35,36,000/- was spent on non-eligible projects. As the deduction u/s.35AC of the Act is admissible in respect of amount spent on eligible projects, the amount spent by HMRI towardsineligible project was not found eligible for deduction u/s 35AC of the Act. The AO had, therefore,disallowed proportionate deduction of Rs.2,36,08,173/- in respect of amount spent on ineligible projects. The addition made by the AO was confirmed by the Ld. CIT(A). The assessee’s alternate claim to allow the deduction u/s.80G of the Act in this respect was also not acceded by the Revenue.
The Ld. AR submitted that assessee had made contribution to an approved institution. If HMRI had spent certain amount for ineligible projects, the assessee had no control over that and the deduction cannot be denied in the hands of the assessee for any wrong done by the Institute. He further submitted that if HMRI spent certain amount on ineligible projects, then the certificate issued by the CBDT should have been cancelled, which was not done. The ld. AR has drawn our attention to provision of Section 35AC of the Act and contended that for any
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wrong done by the institute, no addition can be made in the hands of donor. He has placed relied upon the decision of CIT vs. Gujarat Co-op Milk Marketing Federation Ltd. 43 taxmann.com 398 (Guj.HC) in this regard.
The Ld. DR, on the other hand, submitted that the contribution made by the assessee to HMRI was for specific projects only and if the entire amount was not spent on those approved projects, the AO had rightly made the disallowance. He strongly supported the order of the CIT(A) in this regard.
We have carefully considered the facts of the case. As per provision of Section 35AC of the Act, the assessee is eligible for deduction in respect of payment made to approved institute for carrying out any eligible project or scheme. As long as this condition is satisfied, the donor is eligible to claim the deduction. The Ld. AR had contended that for wrong application of funds by the recipient institute, no disallowance can be made in the hand of the donor and he has drawn our attention to Explanation to Section 35AC(2) of the Act, which reads as under:
“Explanation.—The deduction, to which the assessee is entitled in respect of any sum paid to a public sector company or a local authority or to an association or institution for carrying out the eligible project or scheme referred to in this section applies, shall not be denied merely on the ground that subsequent to the payment of such sum by the assessee,— (a) the approval granted to such association or institution has been withdrawn; or
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(b) the notification notifying the eligible project or scheme carried out by the public sector company or local authority or association or institution has been withdrawn.” It is apparent from the above explanation that the deduction to the donor cannot be denied even in a case where the approval of the institute is withdrawn after the date of payment by the donor or where the notification in respect of eligible project or scheme is also withdrawn. Thus, the prime requirement for deduction under this section is that the payment is made by an assessee to an approved institute for carrying out any eligible project or scheme. It is found that this condition is fulfilled in the case of the assessee. Merely because the approved institute has applied the funds towards ineligible project or scheme, this cannot be a ground to deny the deduction in the hands of the assessee. The provision of Section 35AC(6) of the Act further stipulates that where the approval granted to the institute is withdrawn or where the approval for project or scheme is withdrawn then the amount received by the approved institute will be treated as deemed income of such approved institute only. It is, thus, crystal clear from this provision that for the default of not spending amount for eligible projects, action can be taken only in the hands of the doneeinstitute and not in the hands of the donor.
It was held by Hon’ble Gujarat High Court in the case of Gujarat Co-op Milk Marketing Federation Ltd. (supra) that if the donee trust doesn’t fulfil the conditions as stipulated u/s. 80G of the Act, it will not have any effect on the deduction in the hands of the donor. Though, this decision was rendered in
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the context of deduction u/s. 80G of the Act, the ratio of this decision is equally applicable in respect of deduction u/s. 35AC of the Act. Considering the provision of Section 35AC of the Act as discussed above and also the decision of the Jurisdictional High Court, we are of the considered opinion that no disallowance of claim u/s. 35AC of the Act should have been made in the hands of the assessee for the default on the part of the approved institute.Accordingly, the addition made on account of proportionate disallowance of claim u/s. 35AC of the Act is deleted. The ground is allowed.
Ground No.4 was only an alternate claim for deduction u/s.80G of the Act, in case the deduction u/s.35AC of the Act was not found eligible. In view of our decision in respect of Ground No.3, this Ground has become infructuous, hence dismissed.
Ground No.5 – Disallowance of guarantee commission
The AO disallowed 50% of corporate guarantee commission paid to the associate concern M/s. Piramal Enterprises Ltd. who had extended guarantee for various loans taken by the assessee from HFDC Bank, Kotak Bank, Axis bank, IndusInd Bank & SBICAP Trustee Co. etc. The corporate guarantee commission was paid @ 1.5% to 1.8% per annum. The AO found that the rate of guarantee commission was excessive and, therefore, disallowed 50% of the guarantee commission paid, which has been upheld by the Ld. CIT(A).
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The ld. AR submitted that similar guarantee commission payment was claimed in the earlier years and there was no disallowance made by the department. Further that the AO did not invoke the provision of Section 40A(2)(b) of the Act to make this disallowance. He submitted that the onus was on the AO to demonstrate that the expenditure incurred was excessive or unreasonable, which was not discharged while making this disallowance.
The ld. DR supported the order of the lower authorities on this issue.
We have carefully considered the facts of the case and the rival submissions. The AO has not disputed the genuineness of the guarantee commission paid. Though it is mentioned in the assessment order that there was no need for paying guarantee commission to Piramal Enterprises Ltd., a group company, he did not disallow the entire guarantee commission. The AO has treated the guarantee commission as excessive and disallowed 50% of the claim without bringing on record any comparable case. As rightly pointed out by the assessee the onus was on the department to demonstrate that the expenditure incurred was excessive or unreasonable by brining on record guarantee commission payment in comparable cases. The AO has also not given any reason for disallowing 50% of guarantee commission payment. Further, the provision of Section 40A(2)(b) of the Act was not invoked before making adhoc disallowance of 50% of
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guarantee commission. Even in the case where the provision of Section 40A is invoked, the AO has to establish that the expenditure was excessive or unreasonable having regard to fair market value of the payment made or the legitimate needs of the business. The fact that similar guarantee commission was claimed in the past years which was allowed by the department has also not been disputed. The disallowance made by the AO is based on mere assumption and presumption, which cannot be upheld. Accordingly, 50% disallowance out of corporate guarantee commission made by the Revenue is deleted. The ground is allowed.
Ground No.6 – Short credit of TDS
The ld. AR submitted that full credit of tax deducted at source of Rs.14,36,36,876/- as claimed in the return of income was not allowed by the AO. The assessee had filed reconciliation of TDS as per Form 26AS and TDS as claimed in the return. The assessee had also filed a rectification application u/s. 154 of the Act dated 12.12.2016 for allowing full credit of TDs claim. The AO is directed to verify the claim of TDS as made in Income Tax Return and also the re- conciliation statement filed by the assessee. The credit for TDS claim should be allowed in accordance with provision of Section 199 of the Act. The ground is allowed for statistical purpose.
Ground No.7 – Levy of interest/s.234A of the Act
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The ld. AR submitted that the due date of filing of Income Tax Return for this year was extended by the CBDT. The assessee had paid all the taxes within the original due date of filing of return i.e. before 30th September, 2017. Under the circumstances, no interest u/s. 234A of the Act should have been charged. In this regard, reliance was placed on the decision of Hon’ble Gujarat High Court in the case of All Gujarat Federation of Tax Consultants vs. CBDT, [2014] 50 taxmann.com 115 (Guj.HC).
Ld. DR, on the other hand, submitted that charging of interest u/s. 234A of the Act was mandatory.
We have carefully considered the submissions of the assessee. Hon’ble Gujarat High Court in the case of All Gujarat Federation of Tax Consultants (supra) held as under:
“62. Such extension needs to be granted with the qualification that the same may not result into non-charging of interest under section 234A. Simply put, while extending the period of filing of the tax return and granting benefit of such extension for all other provisions, interest charged under section 234A for late filing of return would be still permitted to be levied, if the Board so choses for the period commencing from 1.10.2014 to the actual date of filing of the return of income. Those tax payers covered under these provisions if choose to pay the amount of tax on or before the 30th September, 2014, no interest in any case would be levied despite their filing of return after the 30th September, 2014.” The due date of filing of return for A.Y. 2014-15 was 30th September, 2014, which was extended by the CBDT. While extending the date of filing of return, interest chargeable u/s. 234A of the Act for late filing of return was still permissible. The Hon’ble Gujarat High Court had directed that in case of tax payers who have paid the entire amount of tax on or before 30th
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September, 2014, no interest for late filing of return may be levied despite their filing of return after 30th September, 2014. As the decision of the Jurisdictional High Court is binding, the department is directed to verify whether the entire amount of tax was paid by the assessee by 30th September, 2014 and if yes, then follow the direction of the Hon’ble Court regarding non- charging of interest u/s.234A of the Act.The ground is allowed for statistical purpose.
In the result, appeal preferred by the assessee is partly allowed.
This Order pronounced on 07/06/2024
Sd/- Sd/- (T.R. SENTHIL KUMAR) (NARENDRA PRASAD SINHA) JUDICIAL MEMBER ACCOUNTANT MEMBER Ahmedabad; Dated 07 /06/2024 S. K. SINHA आदेश क� �ितिलिप अ�ेिषत आदेश क� �ितिलिप अ�ेिषत/Copy of the Order forwarded to : आदेश क� �ितिलिप अ�ेिषत आदेश क� �ितिलिप अ�ेिषत 1. अपीलाथ� / The Appellant ��यथ� / The Respondent. 2. संबंिधत आयकर आयु� / Concerned CIT 3. 4. आयकर आयु�(अपील) / The CIT(A)- 5. िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad 6. गाड� फाईल / Guard file. आदेशानुसार आदेशानुसार/ BY ORDER, आदेशानुसार आदेशानुसार
उप/सहायक पंजीकार उप सहायक पंजीकार (Dy./Asstt.Registrar) उप उप सहायक पंजीकार सहायक पंजीकार आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण, अहमदाबाद आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण अहमदाबाद अहमदाबाद / ITAT, Ahmedabad अहमदाबाद