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Income Tax Appellate Tribunal, RAIPUR BENCH, RAIPUR
Before: SHRI RAVISH SOOD & SHRI ARUN KHODPIA
आदेश / ORDER PER RAVISH SOOD, JM: The present appeal filed by the department is directed against the order passed by the CIT(Appeals)-II, Raipur, dated 23.03.2018, which in turn arises from the order passed by the A.O under Sec.143(3) of the Income-Tax Act, 1961 (for short ‘the Act’) dated 30.03.2016 for assessment year 2013-14. The department has assailed the impugned order on the following grounds of appeal before us : 1. "On the facts and in the circumstances of the case the Ld. CIT(Appeals) erred in not appreciating that there existed incriminating seized material which showed that the assessee company has indulged in unaccounted production by suppressing its yield, particularly in SMS division." 2. "On the facts and in the circumstances of the case, the Ld. CIT(Appeals) erred in deleting the addition of Rs.3,64,59,167/- by not appreciating that the books of accounts are not reliable in view of the evidence seized during the course of search reflecting suppression of production yield. Therefore, when there is no change in the business and the modus operandi, the CIT(A) ought to have accepted 89% as the yield also." 3. "On the facts and in the circumstances of the case, the Ld. CIT(Appeals) erred in deleting the disallowance of Rs.10,44,025/- made by the AO u/s. 14A r. w. r. 8D without appreciating the fact that section 14A shall be worked out even if the assessee does not have any tax free income as clarified by the CBDT as per circular no.05 of 2014 dated 11th Feb. 2014 and that the assessee had made huge investments out of interest bearing funds." 4. "The appellant reserves his right to add, amend or alter the grounds of appeals on or before the date; the appeal is finally heard for disposal."
Succinctly stated, the assessee company which is engaged in the business of manufacturing of steel structural and M.S. Billets through its
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two divisions, viz. (i) Rolling Mill Division (RMD); and (ii) Steel Melting Shop (SMS) division had e-filed its return of income for the assessment year 2013- 14 on 24.09.2013, declaring an income of Rs. Nil. Subsequently, the case of the assessee company was selected for scrutiny assessment u/s.143(2) of the Act.
During the course of the assessment proceedings, it was observed by the A.O that a search and seizure action u/s.132 of the Act was conducted on 17.10.2011 at the business premises of the assessee company. The A.O observed that incriminating documents seized during the course of the search proceedings inter alia revealed that the assessee company had indulged into unaccounted production by suppressing its yield, particularly in its SMS division. It was observed by him that as the annual average yield of the assesee company during the period relevant to block period i.e. A.Ys. 2006-07 to 2012-13 was found less than the annual average yield of 89%, therefore, his predecessor while framing the block assessment vide his order passed u/ss.153A/143(3), dated 27.03.2014 had made an addition on the said count in its hands. The A.O observed that though the aforesaid addition towards suppressed yield in the block assessment was on appeal vacated by the CIT(Appeals), however, the department had not accepted his order and have carried the matter in appeal before the Tribunal and the same was pending adjudication on date.
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The A.O noticed that the assessee during the year under consideration i.e A.Y.2013-14 had shown yield percentage of 85% in its SMS/CCM division, which was lower than the average annual yield percentage of 89% in SMS division. Apart from that, the A.O observed that the assessee during the year in question had shown negative GP rate of (-) 0.84% as in comparison to the last three preceding years wherein the GP rate was reflected at 3.08%, 2.93% and 3.15%, respectively. It was further observed by him that though the turnover of the assessee company had dropped around 33% as in comparison to that of its preceding year, and its claim for certain expenses, viz. interest paid, commission paid and depreciation had either remained at par or was less than those of the last year, however, its net profit had dropped to an amount of (-) Rs. 1.42 Crore as in comparison to the net profit of Rs.8.69 crore shown in the preceding year. The A.O considering the aforesaid facts was of the view that the books of account of the assessee company could not be relied upon, and thus, rejected the same u/s. 145(3) of the Act. The A.O further observing that the assessee’s yield percentage of 85% in Steel Melting Shop (SMS)/Continuous Casting Machine (CCM) was lower than the average yield in the industry of 89% that was adopted by his predecessor while framing of the block assessment in its case for the last seven years, thus, called upon it to put forth an explanation
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as to why the same may not be adopted to work out its suppressed yield for the year under consideration, as under:-
F.Y Total Total Raw Yield Production Difference Difference in production Material (C.C.M) with Yield in Production (MT) Consumed (In MT) of 89% (In production (in Rs.) (C.C.M Div.) (C.C.M) (in MT) (in MT) MT) 2012-13 24,815.70 29,195.50 85.00 25,983.995 1168.295 3,64,59,157 (@ Rs.31,207.15 PMT)
The assessee objected to the rejection of its books of account by the A.O u/s. 145(3) of the Act. It was the claim of the assessee that as it had maintained regular books of account which were subjected to audit; all its purchases and sales along with the quantitative details were available for verification; requisite records prescribed under the excise rules as per the mandate of law were being maintained, and no discrepancy in its records had been pointed out, therefore, its books of account could not be rejected solely for the reason that despite decrease in its turnover the expenses had more or less remained static. Also the assessee objected to adoption of yield of CCM division at 89% as against 85% that was shown during the year under consideration for the standalone reason that the said rate of yield was adopted while framing of the block assessment in its case by the then A.O.
Further, the A.O observed that though the assessee company had made substantial investment of Rs.3,80,10,000/- in shares of M/s Devi Iron
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and Power Pvt. Ltd, however, no part of the expenditure was on a suo-motto basis offered by it for disallowance u/s.14A of the Act. The A.O on the basis of the aforesaid fact called upon the assessee to explain as to why an amount of Rs.10,44,025/- out of interest expenses may not be disallowed u/s.14A of the Act. In reply, it was stated by the assessee that not only it had not earned any exempt income during the year under consideration, but in fact no part of the expenditure claimed as deduction was relatable to earning of any exempt income. Alternatively, it was the claim of the assessee that as the investments in question were made for the purpose of strategic control over other entities, therefore, for the said reason also no disallowance of any part of the expenditure was called for u/s.14A of the Act.
The A.O after deliberating at length on the contentions advanced by the assessee was however not persuaded to accept the same. The A.O was of the view that the yield in the SMS division of 85% was substantially low as in comparison to the average annual yield of 89% that was adopted by his predecessor while framing the block assessment in its case for A.Y.2006- 07 to A.Y 2012-13. Accordingly, the A.O on the basis of his aforesaid deliberations worked out the yield of the assessee at 89% and made an addition of Rs.3,64,59,157/- [1168.295 MT @ Rs. 31,207.15 PMT].
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The A.O after making the aforesaid addition/disallowance vide his order passed u/s.143(3), dated 30.03.2016 scaled down the returned loss of the assessee company to an amount of (-) Rs. 4,43,18,423/-.
Aggrieved the assessee carried the matter in appeal before the CIT(Appeals). The CIT(Appeals) observed that the addition as regards the alleged suppressed yield of SMS/CCM of 1168.295 MT of Rs.3,64,59,157/- was made by the A.O, for the reason that the same shown during the year at 85% was lower than that as was adopted by his predecessor while framing the assessments in its case for the block period i.e A.Ys. 2006-07 to 2011- 12 and A.Y.2012-13, vide his order passed u/s.153A r.w.s. 143(3), dated 27.03.2014. It was further observed by the CIT(Appeals) that the books of account of the assessee were rejected by the A.O solely for the reason that its GP rate for the year under consideration had drastically fallen as in comparison to those of the preceding years.
The CIT(Appeals) observed that it was the claim of the assessee before him that the comparative fall in the GP rate was for multiple reasons, viz. (i) that as in comparison to the F.Y.2009-10 the cost of power in the case of Rolling Mill Division had increased by nearly 85%; (ii). that as in comparison to the F.Y.2009-10 the cost of power in the case of SMS division had increased by 85%; (iii). that there was also increase in the cost of raw material and inputs in the rolling mill division such as cost of blooms and
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billets; (iv) that there was increase in the cost of inputs of the SMS division; and (v) that during the year under consideration iron and steel sector had been going through a challenging phase owing to sluggish domestic demand and constraints placed on iron ore supply along with steep rise in iron ore prices. The CIT(Appeals) observed that the A.O without pointing out any irregularity or defect in the books of accounts, bills and vouchers and other records maintained by the assessee could not have justifiably rejected its books of accounts u/s.145(3) of the Act. It was observed by the CIT(Appeals) that for the standalone reason that the assessee’s yield of 85% in the SMS division during the year was less than 89% as was adopted by his predecessor while framing the assessment in its case for the preceding years could not justify rejection of its books of accounts. It was observed by him that as the facts and circumstances of each year were to be considered separately, thus, there was no justification for the A.O in concluding that as the nature of the assessee’s business had remained the same, therefore, its yield for the year under consideration should have remained the same as that of the preceding years. The CIT(Appeals) further observed that though the A.O had heavily relied on the yield of 89% for the SMS division as was adopted by his predecessor while framing the assessment in the case of the assessee for the block period i.e. A.Y.2006-07 to A.Y 2012-13, but a perusal of the records revealed that the adoption of the said rate of yield in the preceding years was itself not based on any seized material which would
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have established that the assessee had indulged in any unaccounted production and unaccounted sales. The CIT(Appeals) observed that though the A.O had adopted the yield in SMS division at 89% by relying on the order that was passed by his predecessor while framing the assessment u/ss.153A/143(3) of the Act, dated 27.03.2014 for the block period i.e. A.Y. 2006-07 to A.Y 2011-12 and A.Y 2012-13, however, the same thereafter on appeal had been vacated by his predecessor. It was further noticed by him that that the A.O had categorically observed that though the block assessment was on appeal vacated by the then CIT(Appeals), however, his order was not accepted by the department and had ben assailed before the Tribunal which was pending adjudication on date.
The CIT(Appeals) called upon the A.O to explain the basis that was adopted by the department for taking yield at 89% in the case of M/s. Mahamaya Steel Industries Limited, a group company of the assessee which was also engaged in the same line of business. In reply, it was stated by the A.O that the same was on the basis of assessment which was framed in the case of the aforesaid group company, viz. M/s. Mahamaya Steel Industries Limited (supra) for the block period A.Y 2006-07 to A.Y 2012-13. It was observed by the CIT(Appeals) that the aforesaid addition in the case of M/s. Mahamaya Steel Industries Limited (supra), which in turn was based on adoption of the yield in the SMS division at 89% in the latters block
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assessment was on appeal vacated by his predecessor. It was observed by the CIT(Appeals) that the A.O had grossly erred in law and the facts of the case in concluding that the yield in SMS division of the assessee company ought to have been static as in comparison to the preceding years. It was further observed by the CIT(Appeals) that as the assessee was an excisable unit and was filing its excise and VAT returns, and had also got its books of account audited, therefore, the same could not have been rejected for the standalone reason that its yield of 85% in the SMS division during the year under consideration was lower than the yield of 89% that was adopted by his predecessor while framing the assessment in its case for the block period A.Y.2006-07 to A.Y 2012-13. Accordingly, the CIT(Appeals) after relying on the orders which were passed by his predecessor for the A.Y.2006-07, A.Y 2008-09 to A.Y 2012-13, in Appeal No. 739 to 744, vacated the adverse inferences which were drawn by the A.O for dislodging the disclosed yield of the SMS division of the assessee company for the year under consideration. The CIT(Appeals) after taking due cognizance of the multi-facet reasons which as explained by the assessee had resulted to comparatively lower GP/NP rate during the year under consideration, observed, that as the profit disclosed by the assessee was substantially higher than that disclosed by similarly placed units in the industry, therefore, no adverse inferences as regards the same was liable to be drawn and vacated the addition of Rs.3,64,59,157/- made by the A.O.
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As regards the disallowance of Rs.10,44,025/- made by the A.O u/s.14A of the Act, it was observed by the CIT(Appeals) that the assessee had claimed that no expenditure was incurred in relation to the exempt income and all the investments were made in the preceding years and not during the year under consideration. It was further observed by the CIT(Appeals) that the cash profits earned by the assessee during the year in which the investments were made in the shares of group companies was more than the amount of investment. Also, it was observed by the CIT(Appeals) that there were sufficient cash profits available with the assessee for making investment in shares. On the basis of his aforesaid observations the CIT(Appeals) vacated the disallowance of Rs.10,44,025/- made by the A.O u/s.14A r.w Rule 8D.
The revenue being aggrieved with the order of the CIT(Appeals) has carried the matter in appeal before us.
We have given a thoughtful consideration and are of the considered view that in so far the disallowance made by the A.O u/s.14A r.w.r.8D is concerned, now when the assessee company had admittedly not received any exempt income during the year under consideration, therefore, no disallowance u/s.14A of the Act was called for in its hands. Our aforesaid view is fortified by the judgment of the Hon’ble Supreme Court in the case
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of CIT Vs. Chettinad Logistics Pvt. Ltd. (2018) 257 Taxmann 2(SC) and also those of the Hon’ble High Court of Delhi in the case of Cheminvest Limited Vs. CIT, (2015) 378 ITR 33 (Delhi) and CIT Vs. Holcim India P. Ltd. 57 Taxmann.com 28(2015). The ld. A.R submitted that as per the settled position of law in absence of any exempt income no disallowance u/s.14A could have even otherwise been made in the hands of the assessee. In the backdrop of the facts involved in the case before us r/w. the aforesaid settled position of law, we find substance in the claim of the Ld. AR that now when the assessee company had not received any exempt dividend income during the year under consideration, therefore, no disallowance u/s.14A of the Act was warranted in its case. Alternatively, there is substance in the claim of the Ld. AR that now when the interest free funds available with the assessee were in excess of the exempt income yielding investments, therefore, no disallowance of any part of the interest expenditure could have been made in its hands. Our aforesaid view that when interest free funds and interest- bearing funds are available, then, a presumption would arise that the interest free advances have been given out of interest free funds is supported by the judgment of the Hon’ble Supreme Court in the case of South Indian Bank Ltd. Vs. CIT (2021) 438 ITR 001 (SC). Also, a similar view had been taken by the Hon’ble High Court of Bombay in the case of CIT Vs. HDFC Bank Ltd. (2014) 89 CCH 185 (Bom.) We, thus, in terms of our aforesaid observations concur with the CIT(Appeals) who had rightly vacated the
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disallowance u/s 14A of Rs.10,44,025/- made by the A.O. Thus, the Ground of appeal No.3 raised by the revenue is dismissed in terms of our aforesaid observations.
We shall now advert to the grievance of the revenue that the CIT(Appeals) had erred in vacating the addition of Rs.3,64,59,167/- which was made by the A.O by substituting the yield of 85% in the SMS division of the assessee company, by that as was adopted by his predecessor i.e at 89% while framing the block assessment in the case of the assessee for A.Y. 2006- 07 to A.Y.2011-12 and A.Y.2012-13.
We have given a thoughtful consideration to the aforesaid issue in hand, and are inclined to concur with the view taken by the CIT(Appeals) that the books of account of the assessee could not have been rejected by the A.O for the standalone reason that yield in the SMS division of the assessee for the year under consideration was found to be on the lower side as in comparison to the impugned yield as was adopted by his predecessor while framing the block assessment in its case vide order passed u/s.153A/143(3) dated 27.03.2014 for A.Y. 2006-07 to A.Y.2011-12 and A.Y.2012-13. We may herein observe that it is a matter of fact borne from record that yield in SMS division of the assessee in the preceding year i.e. A.Y.2006-07 to A.Y.2011-2 and A.Y.2012-13 that was adopted by the A.O while framing assessment u/s.153A/143(3), dated 27.03.2014 had
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thereafter been vacated by the CIT(Appeals), and his order had thereafter been upheld by the Tribunal while disposing off the appeals filed by the revenue for the A.Y.2006-07, A.Y.2008-09 to A.Y 2012-13 in ITA No.250 to 255/RPR/2014, dated 25.10.2021, Page 1 to 72 of APB.
We may herein observe that as held by the CIT(Appeals) and, rightly so, the books of account of the assessee could not have been validly rejected by the A.O u/s.145(3) of the Act for the reason that the profit of the assessee had witnessed a decline as in comparison to the preceding years. At this stage, we may herein observe that the assessee had duly explained the multi-facet reasons which had resulted to a comparative decline in its GP rate for year under consideration, viz. (i) that as in comparison to the F.Y.2009-10 the cost of power in the case of Rolling Mill Division had increased by nearly 85%; (ii). that as in comparison to the F.Y.2009-10 the cost of power in the case of SMS division had increased by 85%; (iii). that there was also increase in the cost of raw material and inputs in the rolling mill division such as cost of blooms and billets; (iv) that there was increase in the cost of inputs in the SMS division; and (v) that during the year under consideration iron and steel sector had been going through a challenging phase owing to sluggish domestic demand and constraints placed on iron ore supply along with steep rise in iron ore prices. Also, we concur with the view taken by the CIT(Appeals) that now when no irregularity or defect had
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been pointed out by the A.O in the books of account of the assessee, bills and vouchers and other documentary evidences pertaining to the year under consideration, therefore, there was no justification for him to have rejected its books of account u/s.145(3) of the Act, for the standalone reason that its GP rate had witnessed a decline as in comparison to the preceding years. Also, as observed by the CIT(Appeals) and, rightly so, as the assessee company being an excisable unit was regularly filing its excise and VAT returns, therefore, rejection of its duly audited books of account without pointing out any defect or irregularity by the A.O does not merit acceptance.
On merits, the rejection by the A.O of the yield in the SMS division of 85% (approx.) as was disclosed by the assessee during the year and substitution of the same by the yield of 89% that was taken by his predecessor while framing the block assessment in its case vide order passed u/ss. 153A/143(3), dated 27.03.2014 for A.Y.2006-07 to A.Y.2011- 12 and A.Y.2012-13, in our considered view had rightly been vacated by the CIT(Appeals). As observed by the CIT(Appeals) and, rightly so, as every year is an independent year, therefore, there was no justification on the part of the A.O in summarily adopting the results of the preceding years as against that revealed by the assessee on the basis of its audited books of account and supporting documentary evidences for the year under consideration. Also, we cannot remain oblivion of the fact that the adoption by the A.O of
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the yield in SMS division of the assessee company at 89% while framing the block assessment in its case for A.Y.2006-07, 2008-09 to 2012-13 u/ss. 153A/143(3), dated 27.03.2014 had been vacated by the CIT(Appeals) vide his order dated 21.07.2014, which order had thereafter been upheld by the Tribunal vide its order passed in ITA Nos. 250 to 255/RPR/2014, dated 25.10.2021. Apart from that, we also do not find any basis for adoption of yield in SMS division at 89% by the A.O. Our aforesaid view is fortified by the observation of the CIT(Appeals) that though the yield in SMS division in the case of M/s. Mahamaya Steel Industries Pvt. Ltd. (supra), a similarly placed group entity, was also taken by the A.O at 89% while framing of assessment in its case for A.Y.2006-07 to A.Y 2012-13, however, the same was deleted by the CIT(Appeals) by observing that no incriminating material had surfaced in the course of search proceeding which would support the adoption of the yield as was done by the A.O.
Be that as it may, we are of the considered view that now when the adoption of yield in the SMS division at 89% by the A.O during the year under consideration i.e A.Y 2013-14 was in itself based on the view that was taken by his predecessor while framing the block assessment in its case vide order passed u/ss. 153A/143(3), dated 27.03.2014 for A.Y.2006-07 to A.Y.2011-12 and A.Y.2012-13, which had been vacated by the CIT(Appeals) vide his consolidated order dated 21.07.2014, and the same thereafter had
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been upheld by the Tribunal in ITA Nos. 250 to 255/RPR/2014, dated 25.10.2021, therefore, there remains no basis for sustaining the aforesaid view of the A.O during the year under consideration. For the sake of clarity the relevant observation of the Tribunal in ITA Nos. 250 to 255/RPR/2014 dated 25.10.2021 on the issue in question is culled out as under:- “27.5 The CIT(A) in our mind has analysed the factual matrix threadbare. Without repeating all the observations of the CIT(A), we find ourselves in complete agreement with the conclusion drawn by the CIT(A). The CIT(A) has objectively analyzed the factual situation and found complete absence of any adverse material against the assessee which can support the allegation of the AO towards unaccounted production presumed on the basis of alleged low yield declared by the assessee. On facts, the CIT(A) has found that the yield declared by the assessee is neither low nor the book results could be impeached by some tangible material to indulge in rejection of books of accounts. We see no discernible error whatsoever in the process of reasoning adopted by the CIT(A) while reversing the totally untenable action of the AO based on extraneous considerations. 27.6 Significantly, it is also pertinent here to note that identical issue cropped in the case of a group co. (Mahamaya Steel Industries Ltd.) in the same search and engaged in the same business. The standard yield of 89% adopted in that case was set aside by the CIT(A) and book results were accepted in the identical factual matrix. The Revenue challenged the reversal of additions on account of lower yield. The Co-ordinate bench in DCIT vs. Mahamaya Steel Industries Ltd. ITA No. 232-235/ RPR/ 2014 order dated 7/11/2019 in strikingly similar factual matrix involving same issue and arising from same search, endorsed the order of CIT(A) in relation to AY 2009-10-2013 and struck down the additions made by AO. Hence, the issue, in any case, is not res integra any more in the light of decision of the co-ordinate bench. 27.7 Whatever way we see, case of the revenue has little merit and thus unsustainable. We, thus, decline to interfere with the order of the CIT(A) on this score. We, thus, in terms of our aforesaid observations concur with the view taken by the CIT(Appeals), who in our considered view had rightly vacated the rejection of the books of accounts of the assessee by the A.O u/s.145(3) of the Act, as well as had rightly set-aside the adoption of yield in SMS division
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of the assessee company at 89% as against that disclosed by the assessee company on the basis of its duly audited books of accounts for the year under consideration at 85%. Thus, the Grounds of appeal No.(s) 1 & 2 raised by the revenue are dismissed in terms of our aforesaid observations.
The Ground of appeal No.4 being general in nature is dismissed as 19. not pressed.
In the result, appeal of the revenue is dismissed in terms of our aforesaid observations. Order pronounced under rule 34(4) of the Appellate Tribunal Rules, 1963, by placing the details on the notice board. Sd/- Sd/- ARUN KHODPIA RAVISH SOOD (ACCOUNTANT MEMBER) (JUDICIAL MEMBER) रायपुर/ RAIPUR ; �दनांक / Dated : 17th October, 2022 ***SB आदेश क� ��त�ल�प अ�े�षत / Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant. 2. ��यथ� / The Respondent. 3. The CIT(Appeals)-II, Raipur (C.G) 4. The Pr. CIT (Central), Bhopal (C.G) 5.�वभागीय ��त�न�ध, आयकर अपील�य अ�धकरण, रायपुर ब�च, रायपुर / DR, ITAT, Raipur Bench, Raipur. गाड� फ़ाइल / Guard File. 6. आदेशानुसार / BY ORDER, // True Copy// �नजी स�चव / Private Secretary आयकर अपील�य अ�धकरण, रायपुर / ITAT, Raipur.