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Income Tax Appellate Tribunal, KOLKATA ‘A’ BENCH, KOLKATA
Before: Shri P.M. Jagtap & Shri S.S. Viswanethra Ravi
I.T.A. No. 625/KOL./2012 Assessment year: 2008-2009 & ITA Nos. 720 & 721/KOL/2012 Assessment Years: 2008-2009 & 2007-2008 Page 1 of 14
IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA ‘A’ BENCH, KOLKATA
Before Shri P.M. Jagtap, Accountant Member and Shri S.S. Viswanethra Ravi, Judicial Member
I.T.A. No. 625/KOL/2012 Assessment Year: 2008-2009
Deputy Commissioner of Income Tax,..............................................Appellant Circle-7, Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700 069
-Vs.-
M/s. Eco Wheels Private Limited,................................................Respondent 25A, Camac Street, 4 th Floor, Room No. 410, Vardan Building, Kolkata-700 016 [PAN : AABCT 8246 K]
&
I.T.A. Nos. 720 & 721/KOL/ 2012 Assessment Years : 2008-2009 & 2007-2008
M/s. Eco Wheels Private Limited,................................................Appellant 25A, Camac Street, 4 th Floor, Room No. 410, Vardan Building, Kolkata-700 016 [PAN : AABCT 8246 K]
-Vs.- Assistant Commissioner of Income Tax,......................................Respondent Circle-7, Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700 069
Appearances by: Shri Ashok Kumar, Addl. CIT, Sr. D.R., for the Department Shri D.S. Damle, FCA, for the assessee
Date of concluding the hearing : January 11, 2016 Date of pronouncing the order : February 24, 2016
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O R D E R Per Shri P.M. Jagtap:- Out of these three appeals, one appeal being I.T.A. No. 721/KOL/2012 is the appeal filed by the assessee for assessment year 2007-08, while the remaining two appeals being I.T.A. No. 720/KOL/2012 (assessee’s appeal) and I.T.A. No. 625/KOL/2012 (Revenue’s appeal) are cross appeals for assessment year 2008-09. Since the issues involved in all these appeals are common and inter-linked, the same have been heard together and are being disposed of by a single consolidated order for the sake of convenience.
First we shall take up the appeal of the assessee for A.Y. 2007-08 being ITA No. 721/KOL/2012, which is directed against the order of the ld. Commissioner of Income Tax (Appeals)-VIII, Kolkata dated 201.01.2012.
The relevant facts of the case giving rise to this appeal are as follows:- The assessee is a Company, which is engaged in the business of manufacturing, trading and export of Tubeless Tyres, Plastic Rims, Wheel Chairs, Wheel Chair’s Parts, Hand Rims, Crutches, Rollators, Walkers, etc. The return of income for the year under consideration, i.e. A.Y. 2007-08 was filed by it on 31.10.2007 declaring total income at NIL after claiming deduction of Rs.1,91,28,966/- under section 10A of the Income Tax Act, 1961. During the course of assessment proceedings, the claim of the assessee for deduction under section 10A was examined by the Assessing Officer. On such examination, he, inter alia, found that the export turnover taken by the assessee for the purpose of computing deduction under section 10A was inclusive of export of trading goods of Rs.34,70,997/-and domestic sales of Rs.28,96,357/-. According to him,
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these two figures were liable to be excluded from the export turnover for the purpose of computing deduction under section 10A and accordingly he recomputed and restricted the claim of the assesese for deduction under section 10A in the assessment completed under section 143(3) vide an order dated 30.12.2009.
Against the order passed by the Assessing Officer under section 143(3), an appeal was preferred by the assessee before the ld. CIT(Appeals) challenging the validity of the said assessment made by the Assessing Officer as well as disputing, inter alia, the action of the Assessing Officer in reducing the export of trading goods amounting to Rs.34,70,997/- and domestic sales amounting to Rs.28,96,357/- from the export turnover for the purpose of computing deduction under section 10A.
After considering the submissions made by the assessee and perusing the relevant material available on record, the ld. CIT(Appeals) did not find merit in the preliminary issue raised by the assessee challenging the validity of the assessment made by the Assessing Officer under section 143(3) and upholding the validity of the said assessment, he decided this issue against the assessee. He also did not find merit in the contention of the assessee that the export of trading goods of Rs.34,70,997/- and domestic sales of Rs.28,96,357/- were liable to be included in the export turnover for the purpose of computing deduction under section 10A and rejecting the same, he upheld the order of the Assessing Officer on these issues on merit. Aggrieved by the order of the ld. CIT(Appeals), the assessee has preferred this appeal before the Tribunal.
At the time of hearing before us, the ld. Counsel for the assessee has not raised Grounds No. 1 to 5 raised by the assessee in this appeal
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involving the common issue relating to the validity of the assessment made by the Assessing Officer under section 143(3). The same are accordingly dismissed as not pressed.
The issue involved in Ground No. 6 relates to the assessee’s claim for inclusion of the export of trading goods worth Rs.34,70,997/- in the export turnover for the purpose of computing deduction under section 10A.
While examining the claim of the assessee for deduction under section 10A, it was noticed by the Assessing Officer that the export turnover taken by the assessee was inclusive of export of goods worth Rs.34,70,997/-, which were in the nature of trading goods. He found tht the said goods were not manufactured by the assessee but were simply bought from other party and they were exported. According to him, deduction under section 10A was available only for the articles or things manufactured by the assessee and exported and not on the goods purchased from other parties and subsequently exported. He, therefore, excluded the amount of Rs.34,70,997/- from the total export turnover of the assessee for the purpose of computing deduction under section 10A.
Before the ld. CIT(Appeals), it was explained by the assessee that the goods, which had been shown as trading goods, were, in fact, tyres purchased by it from the Holding Company, M/s. Krypton Industries Limited and the same were assembled in its factory with rim and bush to produce the wheels, which were subsequently exported. It was contended that this was not simply a case of export of the same goods, i.e. tyres purchased by the assessee from its Holding Company but wheels were produced out of the said goods as well as other goods by way of assembling before the same were exported. It was contended that the goods purchased by the assessee-company from its Holding Company, i.e.
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tyres thus were only in the nature of material, which was used by the assessee to produce the wheels in its factory for export. It was claimed that there was thus no case of export of trading goods but it was a case of export of goods manufactured by the assessee-company, which could not be excluded from the total export turnover for the purpose of computing deduction under section 10A. This claim of the assessee was not found acceptable by the ld. CIT(Appeals) and he upheld the action of the Assessing Officer in excluding the amount of Rs.34,09,997/- from the export turnover of the assessee for the purpose of computing deduction under section 10A for the following reasons given in his impugned order:- “I have considered the submission of the appellant, perused the assessment order, other materials available on records and carefully gone through the decisions cited case laws including the decision of the Hon’ble Delhi High Court in the case of CIT – vs.- Continental Engineers Limited (2011) 338 ITR 290 (Del) but I am not in agreement with the contention of the A/R of the appellant as even in the instant case the purchases of raw materials are made from the holding company by the appellant company for the purpose of manufacturing, there is no evidence in the form of agreement etc. which would support the argument and therefore the same cannot be considered as export and makes the appellant company eligible to get the deduction u/s. 10A. The facts of the cases relied upon including the case of CIT v Continental Engineers Limited, by the appellant are distinguishable from the facts of the appellant's case. In the instant case the manufacturing/ production activity was claimed to be taken up by the appellant company at the instance of the holding company and claiming deduction u/s.10A of the IT Act, whereas in the referred case, the holding company got its job work done through the sister concern and it itself claimed the deduction u/s. 10A of the I.T. Act. Moreover, as such there was no agreement with the holding company regarding the purchase of raw materials for manufacturing the items to be exported and it is also not explained whether the holding company has also claimed the similar deduction u/s. 10A or not for export of the same item as confirmation of the holding company is not available in this effect. In the light of the above discussion, the action of the AO in denying the benefit of section 10A on such sales of Rs.34,09,997/-“.
The ld. Counsel for the assessee reiterated before us the submissions made on behalf of the assesese before the ld. CIT(Appeals).
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He also invited our attention to the sample copy of relevant bill raised by M/s. Krypton Industries Limited placed at page no. 65 of the paper book to show that the goods purchased by the assessee from the said party were Tubeless Tyres, while the goods exported by the assessee were wheels as per the copy of Invoice placed at page no. 66 of the paper book, manufactured by using the said tyres as well as other products. He contended that it was thus not a case of export of trading goods as wrongly presumed by the Assessing Officer, but was a case of export of goods manufactured by the assessee by using the tyres purchased from its Holding Company as raw material. He contended that the ld. CIT(Appeals), however, could not appreciate this position clearly supported by the documentary evidence in the form of bills and rejected the claim of the assessee for the reasons not germane to the issue.
The ld. D.R., on the other hand, relied on the orders of the authorities below in support of the revenue’s case on this issue and submitted that the reasons given by the ld. CIT(Appeals) in his impugned order while rejecting the claim of the assessee on this issue may be taken into consideration.
We have considered the rival submissions and also perused the relevant material available on record. It is observed that the stand of the assessee on this issue right from the beginning was that there was no export of trading goods but the goods, i.e. tyres purchased by it from the Holding Company were used for manufacturing of wheels, which were ultimately exported by the assessee. This stand of the assessee is duly supported by the documentary evidence in the form of bill raised by M/s. Krypton Industries Limited on the assessee as well as the corresponding export bills raised by the assessee showing specifically the description of goods purchased as tyres and the goods exported as wheels by using the said tyres as raw material. It appears that the ld. CIT(Appeals), however,
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did not appreciate the stand of the assessee on this issue, which was duly supported by the relevant evidence in the form of bills for corresponding purchase and export and rejected the same on the grounds, which as rightly contended by the ld. Counsel for the assesese, are not germane to the issue. We, therefore, set aside the decision of the ld. CIT(Appeals) on this issue and direct the Assessing Officer to include the amount of Rs.34,70,997/- in the export turnover of the assessee for the purpose of computing deduction under section 10A. Ground No. 6 of the assessee’s appeal for A.Y. 2007-08 is accordingly allowed.
The issue involved in Ground No. 7 relates to the assessee’s claim for inclusion of domestic turnover of Rs.28,96,357/- in the export turnover for the purpose of computing deduction under section 10A.
During the year under consideration, the assessee-Company had sold goods amounting to Rs.28,96,357/- to its holding company M/s. Krypton Industries Limited and the said amount was included in the total export turnover for the purpose of computing deduction under section 10A on the ground that M/s. Krypton Industries Limited was also located within the Special Economic Zone and the goods sold by the assessee to them were subsequently exported. This stand of the assessee was not accepted by the Assessing Officer. According to him, export ought to be outside India and the sale made to other SEZ unit within India could not be regarded as export. He, therefore, excluded the amount of Rs.28,96,357/- from the export turnover of the assessee and recomputed and restricted its claim for deduction under section 10A.
Before the ld. CIT(Appeals), the following submissions were made on behalf of the assessee in support of its claim that the sale of goods by one unit to another unit in the same SEZ constituted export turnover for the purpose of computing deduction under section 10A:-
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“The above sales is transfer of good by one unit 10 another unit in the same Special Economic Zone and the same is regarded as export within the meaning of definition of Export under section 2(m) of Special Economic Zone Act, 2005 and section 51 of the said Act provides that this Act would prevail over all other Act and overriding section and this sale within the export Zone be regarded as Export within the meaning of the said Enactment.
The goods transferred to Krypton Industries Limited was meant for export and in fact, the goods manufactured at the factory of the Appellant has been exported by the Holding Company and particulars of such goods exported by the said Holding company against the goods transferred within the meaning of the Special Economic Zone Act, 1961 are annexed herewith. Further Sir, your Appellant cite the following judgments in their favour:
(a) There is a judgment in case of ACIT v Khoday India Ltd. (2009) 33 SOT 178 (Bang) where the assessee contended that the section 10A of the act did not contain the definition of total turnover provided in section 80HHC should be adopted and it was held that for calculating whether export is less that 75% or more one cannot use different yardstick for total turnover for the purpose of section 10A and 80HHC. Hence the department submission that definition of section 80HHC could not be imported was not acceptable view.
(b) In case of ITO v E-lnfrochips Ltd. (2009) 124 TTJ (Ahd) 176, it was decided that the business of the assessee is covered by section 10B and undertaking fulfil all the condition of sub section (2). For default in making declaration to STPI for local sales, 100% EOU did not loose registration with STPI or did not get disqualified as 100% EOU. In view in section 80HHC that in case of domestic sales are less than 25% of total sales, it may be deemed to have export sales.
(c) In case of CIT v Moser Bear Ltd ( 2009) 177 Taxman 42 (Del) it was held by Delhi High Court that since the goods exceeds more than 75% of export turnover out of total turnover, the benefit under section 10A/10B could not be denied to assessee.
(d) In case of T Two International P. Ltd. V ITO (2010) 3 ITR (Tri) 355 (Mum) it was decided that when domestic sale/Turnover did not exceed 75% of total turnover, the benefit under section cannot be denied.
(e) Therefore in another judgment. in case of Tube Investments of India Ltd v ACIT (2009) 117 ITD 239 (Chennai) TM, where it was held that when the domestic sales is more that 25% of total turnover of an assessee, the proportionate benefit should be conferred upon the assessee.
Therefore it is crystal cleared from the above fact and citations that the provisions of sections 10A/10B be read together with section
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80HHC of the act from the purpose of total turnover as there is no definition of word 'Total income' and Domestic income! Turnover below 15% of total turnover shall deemed to be export sales of an assessee. The factory of the appellant is governed by the Special Economic Act, 2005 and according to the act, the meaning of export is defined in the said Act in its sub-section m of section 2 as the same is as under:- Export mean (i) Taking of goods. or providing services, out of India, from Special Economic Zone, by land, sea or air or any other mode, whether physical or otherwise, or
(ii) Supplying goods or providing services, from the Domestic Tariff Area to a Unit or Developed in the same or different Special Economic Zone; or
(iii) Supplying goods or providing services, from one Unit to another Unit or Developers, in the same or different Special Economic Zone.
It is clear from the above definition is vide enough to cover the meaning of export under the said wherein supply of good or services from one Unit to another unit within the same Special Economic Zone or in different Economic Zone or the sale within the Zone by one unit to another will be regarded as Export under the said Act.
Further Sir, section 51 of the said Act over ride the Income Tax Act or any other Law and this wide definition under the Special Act enacted for the special purpose will be prevail over the Income Tax Act, 1961 as apparent from the above position of law.
Therefore it is prayed before you in consider the same as Export turnover of the Appellant and allow the benefit of section 10A of the Act”.
The above submissions made by the assessee did not find favour with the ld. CIT(Appeals) and he proceeded to uphold the action of the Assessing Officer in excluding the sale of the assessee made to another unit in the SEZ amounting to Rs.28,96,357/- from the export turnover of the assessee for the purpose of computing deduction under section 10A for the following reasons given in his impugned order:- “I have gone through the submission of the appellant carefully considered the decisions of the Hon'ble Delhi High Court and the ITAT Ahmedabad, Chennai, Bangalore and Mumbai relied upon by the appellant perused the impugned assessment order and the available materials on record. However, I am not in
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agreement with the contention of the A/R of the appellant as in the instant case the sale made to the holding company by the appellant company which cannot be considered as exports since the sale effected within the country. The facts of the cases relied upon by the appellant are distinguishable from the facts of the appellant's case. In the case or the Tata Elxsi Ltd. –vs.- CIT 208 reported in 115 TTJ 423 the Hon'ble Bangalore Tribunal, it is held that sales of software to one STP to another STP within the country cannot be treated as deemed export for the purpose of exemption is 10A of the IT Act, 1961. Moreover, as such there was no agreement with the holding company to manufacture the items to be exported and it is also explained whether the holding company has also claimed the similar deduction u/s. 10A or not for export of the same item as no confirmation of the holding company is available in this effect, Keeping in view the entirety of the facts of the appellant's case considering the legal position and respectfully following the decision of Hon'ble Bangalore Tribunal in the case of Tata Elxsi Ltd –vs. CIT 208 (supra), I am of the opinion that the sales effected to the holding concern from the appellant company cannot he considered as Export Turnover of the appellant company and the appellant is also not entitled to get the benefit of section 10A of the Act. Therefore, the disallowance made by the AO on this account is upheld”.
The ld. Counsel for the assessee reiterated before us the submissions on behalf of the assessee before the ld. CIT(Appeals) on this issue. He submitted that the sale of goods in question was made by the assesee to another Unit of its Holding Company situated in the same SEZ and the bill for the same was also raised in U.S. Dollars. He contended that such sale is covered by the definition of export given in section 2(m) of the Special Economic Zone Act, 2005, which have overriding effect as per section 51 of the Special Economic Zone Act. As regards the decision of Bangalore Bench of ITAT in the case of Tata Elxsi Limited (supra) relied upon by the ld. CIT(Appals) in his impugned order, he contended that the decision of the Kolkata Special Bench of ITAT in the case of Madhu Jayanti International Limited –vs.- DCIT reported in 137 ITD 377 rendered is in favour of the assessee on this issue, but the benefit of the said decision of Special Bench rendered subsequently was not available to
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the Bangalore Bench of ITAT while deciding the case of Tata Elxsi Limited (supra).
The ld. D.R., on the other hand, relied on the orders of the authorities below in support of the revenue’s case on this issue.
We have considered the rival submissions and also perused the relevant material available on record. It is observed that the supply of goods from one Unit to another Unit in the same or different Special Economic Zone is treated as export as per the definition given in section 2(m) of the Special Economic Zone Act, 2005 and as per the specific provisions contained in section 51 of the SEZ Act, 2005, the provisions of the said Act shall have effect notwithstanding anything in consistent therewith contained in any other law for the time being in force. Section 2(m) of the SEZ Act, 2005 defining ‘export’ thus has overriding effect and since the supply of goods by the assessee-company from its unit in SEZ to another Unit belonging to its Holding Company in the same SEZ is covered by the said definition, we are of the view that the same cannot be excluded from the export turnover of the assessee for the purpose of computing deduction under section 10A. In that view of the matter, we set aside the impugned order of the ld. CIT(Appeals) on this issue and direct the Assessing Officer to include the sale made by the assesese to the Unit of its Holding Company in the same SEZ in the export turnover for the purpose of computing deduction under section 10A. Ground No. 7 of the assessee’s appeal for A.Y. 2007-08 is accordingly allowed.
Now we take up the appeal of the assesese for A.Y. 2008-09 being ITA No. 720/KOL/2012, which is directed against the order of ld. CIT(Appeals)-VIII, Kolkata dated 19.01.2012.
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At the time of hearing before us, the ld. Counsel for the assesee has not pressed Grounds No. 1 to 5 raised by the assessee in this appeal involving the common issue relating to the validity of the assessment made by the Assessing Officer under section 143(3). The same are accordingly dismissed as not pressed.
As regards Ground No. 6 of the assessee’s appeal for A.Y. 2008-09, it is observed that the issue involved therein relating to the assessee’s claim for inclusion of the export of trading goods worth Rs.29,69,050/- in the export turnover for the purpose of computing deduction under section 10A is similar to the one involved in the appeal filed by the assessee for A.Y. 2007-08, which has already been decided by us in the foregoing portion of this order. Since all the material facts relevant to this issue as involved for A.Y. 2008-09 are similar to the one involved for A.Y. 2007-08, we follow the conclusion drawn in A.Y. 2007-08 and direct the Assessing Officer to include the export of trading goods in the export turnover for the purpose of computing deduction under section 10A. Ground No. 6 of the assessee’s appeal for A.Y. 2008-09 is accordingly allowed.
As regards Ground No. 7 of the assessee’s appeal for A.Y. 2008-09, it is observed that the issue involved therein relating to the assessee’s claim for inclusion of domestic turnover of Rs.47,99,800/- in the export turnover for the purpose of computing deduction under section 10A is also similar to the one involved in the appeal filed by the assessee for A.Y. 2007-08, which has already been decided by us in the foregoing portion of this order. Since all the material facts relevant to this issue as involved for A.Y. 2008-09 are similar to the one involved for A.Y. 2007- 08, we follow the conclusion drawn in A.Y. 2007-08 and direct the Assessing Officer to include the turnover of Rs.47,99,800/- in the export turnover for the purpose of computing deduction under section 10A.
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Ground No. 7 of the assessee’s appeal for A.Y. 2008-09 is accordingly allowed.
As regards the Revenue’s appeal being ITA No. 625/KOL/2012 for A.Y. 2008-09, the ld. Counsel for the assessee, at the outset, has pointed out that the tax effect involved in this appeal of the Revenue is less than the revised monetary limit recently fixed by the CBDT vide Circular No. 21/2015 dated 10th December, 2015 at Rs.10,00,000/- for filing the appeal by the Revenue before the Tribunal and this position clearly evident from the grounds raised by the Revenue in this appeal is not disputed even by the ld. D.R. In Circular No. 21/2015 (supra) recently issued by the CBDT, the monetary limit for filing the appeals by the Revenue before the Tribunal has been increased to Rs.10,00,000/- and as clarified in the said Circular, the said monetary limit is applicable retrospectively even to the appeals pending before the Tribunal. The CBDT has also instructed that such pending appeals below this specified tax limit of Rs.10,00,000/- may be withdrawn/ not pressed. Keeping in view the instruction given by the CBDT vide Circular No. 21/2015 dated 10.12.2015, which is squarely applicable in the present case, the appeal filed by the Revenue in this case is treated as withdrawn/not pressed and dismissed accordingly.
In the result, both the appeals being ITA Nos. 720 & 721/KOL/2012 filed by the assessee are partly allowed, whereas the Revenue’s appeal being ITA No. 625/KOL/2012 is dismissed. Order pronounced in the open Court on February 24, 2016. Sd/- Sd/-
(S.S. Viswanethra Ravi) (P.M. Jagtap) Judicial Member Accountant Member Kolkata, the 24th day of February, 2016
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Copies to : (1) Deputy Commissioner of Income Tax, Circle-7, Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700 069
(2) M/s. Eco Wheels Private Limited, 25A, Camac Street, 4 th Floor, Room No. 410, Vardan Building, Kolkata-700 016
(3) Commissioner of Income-tax (Appeals)- VIII, Kolkata (4) Commissioner of Income Tax, Kolkata (5) The Departmental Representative (6) Guard File
By order
Assistant Registrar, Income Tax Appellate Tribunal, Kolkata Benches, Kolkata Laha/Sr. P.S.