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Income Tax Appellate Tribunal, “C” BENCH, PUNE
Before: SHRI INTURI RAMA RAO & SHRI PARTHA SARATHI CHAUDHURY
आयकर अपीलीय अधधकरण “सी” न्यायपीठ पुणे में । IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, PUNE BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND SHRI PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER
आयकर अपील सं. / ITA No. 2294/PUN/2017 धनधाारण वषा / Assessment Year : 2008-09 The Deputy Commissioner of Income Tax, Circle-1(2), Pune. .......अपीलाथी / Appellant बनाम / V/s. Fiat India Automobiles Ltd. B-19A, Ranjangaon MIDC, Tal. Shirur, Pune-412 209 PAN : AAACF1716D ……प्रत्यथी / Respondent Assessee by : Shri Percy Pardiwala Revenue by : Smt. Divya Bajpai
सुनवाई की तारीख / Date of Hearing : 22.10.2021 घोषणा की तारीख / Date of Pronouncement : 26.10.2021 आदेश / ORDER PER PARTHA SARATHI CHAUDHURY, JM: This appeal preferred by the Revenue emanates from the order of the Ld. CIT(Appeals)-13, Pune dated 31.07.2017 for the assessment year 2008-09 passed u/s.143(3) r.w.s.147 of the Income Tax Act, 1961 (hereinafter referred to as „the Act‟) as per the following grounds of appeal on record:
“1. The order of the Ld. Commissioner of Income Tax (Appeals) is contrary to law and to the facts and circumstances of the case. 2. The Ld. Commissioner of Income Tax (Appeals) grossly erred in quashing the reassessment proceedings as the AO has rightly established the failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment.
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The Ld. Commissioner of Income Tax (Appeals) grossly erred in allowing the appeal in favour of assessee whereas the AO has brought out the material on records necessary for assessment and proved that there is escapement of income. 4. The Ld. CIT(A) grossly erred in allowing the appeal in favour of the assessee whereas the AO has passed speaking order against the objection filed by the assessee during the re-assessment proceedings. 5. For these and such other grounds as may be urged at the time of hearing, the order of the Ld. Commissioner of Income Tax (Appeals) may be vacated and that of the Assessing Officer be restored. 6. The appellant craves to add, amend, alter or delete any of the grounds of appeal during the course of appellate proceedings before the Hon‟ble Tribunal.”
That also there is an application under Rule 27 of the Income Tax (Appellate Tribunal) Rules, 1963 filed by the assessee and therein additional grounds has been filed and that the Assessing Officer had erred in passing final assessment order u/s.143(3) r.w.s.147 of the Act dated 17.03.2016 without passing draft assessment order as per the mandate laid down u/s. 144C of the Act.
That at the First Appellate stage, the assessee had submitted that re- opening of assessment was bad in law on two counts. Firstly, re-opening of assessment was done beyond the period of four years without establishing the assessee‟s failure to disclose fully and truly the material facts relating to the assessment. Secondly, the re-opening of assessment cannot be done without any new material on the basis of which the Assessing Officer shall form a belief of escapement of income chargeable to tax. The assessee had relied on several decisions before the Ld. CIT(Appeals) which are on record.
The Ld. CIT(Appeals) after considering the submissions of the assessee and the assessment order observed at Para 2.1.7 of his order that for re- opening of the assessment for the year under consideration i.e. AY 2008-09, the Assessing Officer needs to establish the assessee‟s failure to disclose fully
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and truly material facts at the time of assessment. That further in this case, the notice u/s.148 of the Act was issued on 31.03.2015 i.e. after four years getting over on 31.03.2013 for re-opening of assessment for assessment year 2008-09. The Assessing Officer in the reasons recorded has stated that there was failure on the part of the assessee to disclose fully and truly material facts related to its income in terms of the average margin of the comparable companies.
However, the assessee has pointed out before the Ld. CIT(Appeals) that this contention of the Assessing Officer was incorrect because margin of the comparable companies were submitted during transfer pricing assessment proceedings in compliance to the TPO‟s direction. In this context, it was mentioned by the Ld. CIT (Appeals) that though the assessee has submitted average margins of the comparable companies incorrectly, the same cannot be considered to be a failure on assessee‟s part to disclose fully and truly material facts because what has been wrongly submitted is only the average margin figure and not the margin of the comparable companies in itself. Therefore, it cannot be concluded that the assessee did not fully and truly disclose average margin of the comparable companies. The Ld. CIT(Appeals) held that the Assessing Officer has not established categorically whether the assessee had failed to disclose fully and truly material facts related to the assessment of income.
That with regard to contentions of the assessee regarding non-existence of new materials for the formation of belief, it was opined by the Ld. CIT(Appeals) that it is fundamental that „reason to believe‟ is stronger than the „reason to suspect‟. Therefore, belief shall be formed from a material which would act as a link with the „reason to believe‟. It is a settled position of law that the material on the basis of which, the belief is formed should exist
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in the recorded reasons and the same cannot be found externally. The Ld. CIT(Appeals) at Para 2.1.10 of his order has given categorical finding that there is no new material brought on record on the basis of which „reason to believe‟ could be said to have been formed. This is a case of re-appraisal of the existing facts and re-opening of assessment without new material on record thus was not permissible even if this had been a case where the original return was processed u/s.143(1) of the Act and the assessment order was not passed u/s.143(3) of the Act.
The Ld.CIT(Appeals) on this proposition relied on specific judicial precedents which are on record as per his order. Thereafter, the Ld.CIT(Appeals) held that first of all, the re-opening of assessment for assessment year 2008-09 had to be done within four years i.e. within 31.03.2013 whereas, in the instant case, re-opening was done by issuing notice u/s. 148 of the Act which was issued on 31.03.2015 i.e. beyond the limitation of four years. Similarly also it was held by the Ld.CIT(Appeals) that there was no fresh materials on record brought in by the Assessing Officer for forming „reason to believe‟ that income chargeable to tax has escaped assessment. On these two counts, the Ld. CIT(Appeals) held re-assessment proceedings as invalid in law and had quashed the re-assessment order passed by the Assessing Officer accordingly.
The Revenue being aggrieved by this have filed the instant appeal before us. That before us, the Ld. DR could not refute the fact that the re- assessment proceedings were done beyond the period of limitation of four years in this case. The Ld. DR also could not bring on record any materials/ documentary evidences to demonstrate that any new material was there in the possession of Assessing Officer for formation of „reason to believe‟ that
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income chargeable to tax has escaped assessment so to resort to proceedings u/s. 147/148 of the Act.
Further reading to Section 147 of the Act makes it clear that the pre- requisite condition which can be said to be sine-qua nonest is that the Assessing Officer must have a „reason to believe‟ that the income chargeable to tax has escaped assessment. This had been held by the Hon‟ble Rajasthan High Court in the case of CIT Vs. Shree Rajasthan Syntex Ltd, 313 ITR 231 that the Assessing Officer could not resort to re-assessment proceedings based on „borrowed satisfaction‟ and that it has to be always an independent satisfaction of the Assessing Officer himself obtained from examinations of facts on record.
In the present case before us, there is nothing on record to demonstrate that the Assessing Officer had initiated reassessment proceedings in accordance of any new information in his possession regarding income escaping assessment.
The very provision of Section 147 states that “if the Assessing Officer has „reason to believe‟……..”, meaning thereby that the „reason to believe‟ that an income chargeable to tax has escaped assessment has to be formed independently by the Assessing Officer and he cannot rely on satisfaction by any other agency whatsoever for resorting to provisions of Section 147 of the Act. We find the Hon‟ble Bombay High Court in the case of Pr. Commissioner of Income Tax Vs. Vaman International Pvt. Ltd., ITA No.1940 of 2017 has held that mere reliance by the Assessing Officer on information obtained from the Sales Tax Department or the statements of two persons made before the Sales Tax Department would not be sufficient to treat the purchases as bogus for making addition u/s.69C of the Act.
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Reverting to the facts of the present case, though the aforesaid matter was in relation to addition u/s.69C of the Act and the present case before us is with regard to Section 147/148 of the Act, the guiding principles still is that it is mandatory for the Assessing Officer to conduct independent enquiry and examination of facts to arrive at satisfaction justifying „reason to believe‟ that “income has escaped assessment”.
Considering the totality of facts and circumstances, We are, therefore, of the considered view that the findings of the Ld. CIT(Appeals) needs no interference and the same is upheld.
Now we would examine the ground invoked by assessee under Rule 27 of the Income Tax (Appellate Tribunal) Rules, 1963 stating that since the mandate u/s. 144C of the Act was not complied by the Assessing Officer and for the fact that he has not passed a draft assessment order, therefore, the final assessment order u/s. 143(3) r.w.s.147 of the Act was bad in law and on this count also, the reassessment order ought to have been quashed.
The Ld. Senior Counsel for the assessee before us submitted that in pursuance of Section 144C(1) read with section 143(3) of the Act, the Assessing Officer is necessarily required to forward a draft assessment order, in the first instance to the assessee, if he proposes to make any variation in the income or loss returned which is prejudicial to the interest of such eligible assessee as defined u/s.144C(15)(b) of the Act. The Ld. Senior Counsel also submitted that on receipt of the draft assessment order as per Section 144C(1) of the Act, the assessee is entitled to file its objections before the Dispute Resolution Panel (DRP) and the Assessing Officer as per Section 144C(2) of the Act or it may file its acceptance to such variation before the Assessing Officer. The Assessing Officer has to complete the assessment and
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pass the final assessment order only after directions are issued by the DRP u/s. 144C(5) of the Act and only thereafter, the Assessing Officer could have passed the final assessment order. The Ld. Senior Counsel further submitted that on receipt of the objections u/s.144C(2) of the Act, the DRP shall issue directions u/s.144C(5) of the Act to the Assessing Officer providing guidance to enable completion of the assessment which directions are binding upon the assessee u/s.144C(10) of the Act. He also submitted that the Assessing Officer has to pass the final assessment order u/s. 143(3) r.w.s. 144(13) of the Act in conformity with the directions issued by the DRP and the Assessing Officer is not authorized to pass any final order without the directions of the DRP. Therefore, in view of Section 144C(1) of the Act, the Assessing Officer is first required to pass a draft assessment order and not directly pass a final assessment order.
The Ld. Senior Counsel for the assessee submitted that identical issue was considered by the Hon‟ble Jurisdictional High Court in the case of SHL (India) Private Limited Vs. Deputy Commissioner of Income Tax & Ors, Writ Petition (L) No.11293 of 2021 dated 28th July, 2021 and therein the substantive question of law formulated for adjudication were:
(i) Whether the provisions contained in Section 144C(1) of the Act are mandatory or directory and (ii) Whether there has been a mere procedural error on the part of the Assessing Officer in passing the final assessment order without passing a draft assessment order as required u/s.144C(1) of the Act.
The Hon‟ble Jurisdictional High Court on the issue “whether the provisions of section 144C(1) of the Act are mandatory in nature‟‟ considered the decision of the Hon‟ble Andhra Pradesh High Court in the case of M/s. Zuari Cement Limited Vs. Assistant Commissioner of Income Tax, Writ
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Petition No. 5557 of 2012 decided on 21.02.2013 ( Andhra Pradesh). In this case, the Hon‟ble Andhra Pradesh High Court after considering the provisions of Section 144C(1) of the Act held that provisions of section 144C are mandatory as the Assessing Officer u/s.144C(1) of the Act is mandated to first pass a draft assessment order, communicate it to the assessee, hear his objections and then complete assessment. The relevant extract of the said decision are as follows:
“A reading of the above section shows that if the Assessing Officer proposes to make, on or after 01.10.2009, any variation in the income or loss returned by an assessee, then, notwithstanding anything to the contrary contained in the Act, he shall first pass a draft assessment order, forward it to the assessee and after the assessee files his objections, if any, the Assessing Officer shall complete assessment within one month. The assessee is also given an option to file objections before the Dispute Resolution Panel in which event the latter can issue directions for the guidance of the Assessing Officer to enable him to complete the assessment. In the case of the petitioner, admittedly the TPO suggested an adjustment of Rs.52.14 crores u/s.92CA of the Act on 20.09.2011 and forwarded it to the Assessing Officer and to the assessee under sub- section (3) thereof. The Assessing Officer accepted the variation submitted by the TPO without giving the petitioner any opportunity to object to it and passed the impugned assessment order. As this has occurred after 01.10.2009, the cut off date prescribed in sub-section (1) of S.144C, the Assessing Officer is mandated to first pass a draft assessment order, communicate it to the assessee, hear his objections and then complete assessment. Admittedly this has not been done and the respondent has passed a final assessment order dt.23.12.2011 straight away. Therefore, the impugned order of assessment is clearly contrary to S.144C of the Act and is without jurisdiction, null and void. In this view of the matter, we are of the view that the impugned order of assessment dt.23.12.2011 passed by the respondent is contrary to the mandatory provisions of S.144C of the Act and is passed in violation thereof. Therefore, it is declared as one without jurisdiction, null and void and unenforceable. Consequently, the demand notice dated 23.12.2011 issued by the respondent is set aside.”
The SLP filed by the Revenue against this decision has been dismissed by the Hon‟ble Supreme Court and therefore, it is evident that the provisions of Section 144C(1) are mandatory and not directory.
The Hon‟ble Jurisdictional High Court further referred to one of its earlier decision in the case of International Air Transport Association Vs.
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Deputy Commissioner of Income Tax & Ors, Writ Petition (L) No.351 of 2016 dated 18.02.2016 wherein the Hon‟ble High Court has observed that a draft assessment order passed under Section 144C(1) of the Act bestows certain rights upon an eligible assessee such as to approach the DRP with its objections to such a draft assessment order. This is for the reason that an eligible assessee's grievance can be addressed before a final assessment order is passed and appellate proceedings invoked by it. However, these special rights made available to eligible assessee under Section 144C of the Act are rendered futile, if directly a final order under Section 143(3) of the Act is passed without being preceded by draft assessment order. Thereafter, also the Hon‟ble High Court referred and concurred with the findings of the Hon‟ble Andhra Pradesh High Court in the case of M/s. Zuari Cement Limited Vs. Assistant Commissioner of Income Tax (supra.).
The Hon‟ble Delhi High Court in the case of JCB India Limited Vs. Deputy Commissioner of Income Tax 92017) 85 taxmann.com 155 (Delhi) had also re-emphasizes that the Assessing Officer cannot straight away pass a final assessment order without issuing a draft assessment order under Section 144C(1) of the Act, even in the case of remand of proceedings and that such an omission is not a mere irregularity, but an incurable illegality, which cannot be saved by resorting to Section 292B of the Act by Revenue. Thereafter, the Hon‟ble Jurisdictional High Court in the case of SHL (India) Private Limited Vs. Deputy Commissioner of Income Tax & Ors (supra.) has held and observed as follows:
“25. In our view, the following principles emerge from the above discussion :- (i) that the procedure prescribed under Section 144C of the IT Act is a mandatory procedure and not directory. (ii) failure to follow the procedure under Section 144C(1) would be a jurisdictional error and not merely procedural error or irregularity.
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(iii) therefore, Section 292B of the IT Act cannot save an order passed in breach of the provisions of Section 144C(1), the same being an incurable illegality. 26. It is important to note that Section 144C(1) is a non-obstante provision, which requires its compliance irrespective of the other provisions that may be contained in the IT Act. There is no dispute that Petitioner is an eligible assessee and also there is no dispute as to the applicability of Section 144C. It is also not in dispute that the final Assessment Order has been passed without the draft Assessment Order as contemplated under Section 144C (1) of the IT Act. The Assessing Officer ought to have in the first instance forwarded a draft of the proposed order of assessment to Petitioner, as there was a proposed variation prejudicial to the interest of the assessee. This important step has been completely omitted by the Respondent taking away a very necessary right of Petitioner to file objections to the proposed variation with the DRP and the Assessing Officer, which in our view, strikes to the root of the procedure contemplated by Section 144C. 27. Applying the aforesaid principles to the facts of this case, we are of the view that the failure on the part of the Assessing Officer to follow the procedure under Section 144C(1) is not a merely procedural or inadvertent error, but a breach of a mandatory provision. We are also not impressed with the arguments of the Revenue that the Assessing Officer was under pressure of two charges, as there were timelines to adhere to, since the said timelines from time to time have been extended, the most recent one being to 30th September, 2021. The Revenue ought to have appreciated that the requirement under Section 144C(1) to first pass a draft Assessment Order and to provide a copy thereof to the assessee is a mandatory requirement which gave substantive right to the assessee to object to any variation, that is prejudicial to it. In this case, the order under Section 92CA (3) of the IT Act, proposed to make an adjustment of Rs.107,454,337/- to the arm‟s length price considered as Nil by Petitioner and to that extent the said adjustment was evidently prejudicial to the interest of Petitioner. Depriving Petitioner of this valuable right to raise objection before DRP would be denial of substantive rights to the assessee, for which, in our view, the Assessing Officer has no power under the statute, as the provision clearly mandates the Assessing Officer to pass and furnish a draft Assessment Order in the first instance in such a case. The legislature, in our view, has intended to give an important opportunity to Petitioner, who is an eligible assessee, which in our view, has been taken away. In our view, failure to follow the procedure under Section 144C(1) would be a jurisdictional error and not merely procedural error or a mere irregularity. The Assessment Order has not been passed in accordance with the provisions of Section 144C of the IT Act. This is not an issue, which involves a mistake in the said order, but it involves the power of the Assessing Officer to pass the order. By not following the procedure laid down in Section 144C(1) to pass and furnish a draft Assessment Order to Petitioner and directly passing a final Assessment Order and without giving Petitioner an opportunity to raise objections before the DRP, there is a complete contravention of Section 144C, the Assessing Officer having wrongly assumed jurisdiction to straight away pass the final order. This is not a mere irregularity but an incurable illegality. Even the provisions of Section 292B of the IT Act would not protect such an order as Section 292B of the IT Act cannot be read to confer jurisdiction on the Assessing Officer, where none exists. The Supreme Court decision in the case of Income-Tax Officer Vs. M. Pirai Choodi; [2011] 334 ITR 262 (SC) referred to in the Revenue‟s reply is also not applicable to the issue at hand as that was a case where the assessee was not given an opportunity to cross-examine the concerned witness and which assessee also had a
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statutory appellate remedy which the assessee had failed to avail of, whereas there is no such right available to Petitioner in this case. In fact, Petitioner has lost a substantive right due to the failure of the Respondents to pass and forward a draft assessment order in the first instance on a variance, prejudicial to the interest of Petitioner. In our view, this is clearly a case of jurisdictional error. The final assessment order passed by the Assessing Officer stands vitiated on account of lack of jurisdiction, which is incurable and deserves to be set aside as void ab initio. 28. We, therefore, quash and set aside the impugned Assessment Order, Demand Notice and Penalty Notice, all dated 6th April, 2021 for the Assessment Year 2017-2018.”
Respectfully following the aforesaid decision of the Hon‟ble Jurisdictional High Court, we hold that procedure u/s.144C(1) to pass and furnish draft assessment order to the assessee is a mandatory procedure and the Assessing Officer cannot directly pass the final assessment order. This is not a mere irregularity but an incurable illegality. Even the provisions of Section 292B of the Act would not protect or confer jurisdiction on the Assessing Officer which none exists.
At this time, the Ld. DR raised a contention that the mandatory element of Provisions to section 144C of the Act shall apply to eligible assessee only as contained therein but not in every case. That referring to Section 92CA of the Act, the Ld. DR submitted that on reference to TPO first examination has to be done based on parameters contained in the said provision whether, the assessee is an eligible assessee and only then the mandatory provisions of Section 144C of the Act would apply and not before that.
Per contra, the Ld. Senior Counsel referring to CBDT Instruction No.3/2016 [F No.500/9/2015-APA-II] dated 10.03.2016 submitted that at Para 2 therein provides the basis for which this Instruction has been issued and it reads as follows:
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“2. In terms of the provisions, any income arising from an international transaction or specified domestic transaction between two or more associated enterprises shall be computed having regard to the Arm‟s Length Price. Instruction No.3 was issued on 20th May, 2003 to provide guidance to the Transfer pricing Officers (TPOs) and the Assessing Officers (AOs) to operationalize the transfer pricing provisions and to have procedural uniformity. Due to a number of legislative, procedural and structural changes carried out over the last few years, Instruction No.3 of 2003 was replaced with Instruction No.15/2015, dated 16th October, 2015. After the issuance of Instruction No.15/2015, the Board has received some suggestions and queries, which have been examined in detail. Accordingly, this Instruction is being issued to replace Instruction No.15 of 2015. This Instruction is applicable for both international transactions and specified domestic transactions between associated enterprises. The guidelines on various issues are as follows:”
Thereafter, from Para 3 states under what circumstances reference to TPO has to be done. In this connection, Para 3.2 is of utmost relevance which reads as follows:
“3.2 All the cases selected for scrutiny, either under the Computer Assisted Scrutiny Selection (CASS) system or under the compulsory manual selection system (in accordance with the CBDT‟s annual instructions in this regard- for example. Instruction No.6/2014 for selection in FY 2014-15 and Instruction No.8/2015 for selection in FY 2015-16, on the basis of transfer pricing risk parameters [ in respect of international transactions or specified domestic transactions or both] have to be referred to the TPO by the AO, after obtaining the approval of the jurisdictional Principal Commissioner of Income Tax (PCIT) or Commissioner of Income Tax (CIT). The fact that a case has been selected for scrutiny on a TP risk parameter becomes clear from a perusal of the reasons for which a particular case has been selected and the same are invariably available with the jurisdictional AO. Thus, if the reason or one of the reasons for selection of a case for scrutiny is a TP risk parameter, then the case has to be mandatorily referred to the TPO by the AO, after obtaining the approval of the jurisdictional PCIT or CIT.”
Therefore, it is in respect of each and every case which involves transfer pricing risk parameters and in respect of international transactions or specified domestic transaction or both, they have to be referred to the TPO by the Assessing Officer after obtaining approval of the jurisdictional PCIT or CIT. Therefore, if the reason of selection of case for scrutiny is transfer pricing risk parameters, then the case has to be mandatorily referred to the TPO by the Assessing Officer after obtaining such approval. Thus, the contention of
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the Ld. DR cannot be entertained since the Instruction No.3/2016 (supra.) is clearly binding on the department and it is categorically mentioned therein that any case involving transfer pricing risk parameters in respect of either or both international or domestic transaction, the case mandatorily has to be referred to the TPO by the Assessing Officer after obtaining necessary approval. There is as such no distinction of treatment pertaining to the terms as eligible assessee.
Considering the totality of facts and circumstances and on examination of facts on record and the judicial decisions, we hold, the re-assessment order passed u/s.143(3) r.w.s.147 of the Act as bad in law, void-ab-initio, hence, justified to be quashed. We sustain the relief provided by the Ld. CIT(Appeals) to the assessee.
In the result, appeal of the Revenue is dismissed.
Order pronounced on 26th day of October, 2021.
Sd/- Sd/- INTURI RAMA RAO PARTHA SARATHI CHAUDHURY ACCOUNTANT MEMBER JUDICIAL MEMBER पुणे / Pune; ददनांक / Dated : 26th October, 2021 SB आदेश की प्रधतधलधप अग्रेधषत / Copy of the Order forwarded to : अपीलाथी / The Appellant. 1. प्रत्यथी / The Respondent. 2. 3. The CIT(Appeals)-13, Pune. 4. The Pr. CIT-5, Pune. धवभागीय प्रधतधनधध, आयकर अपीलीय अधधकरण, “सी” बेंच, 5. पुणे / DR, ITAT, “C” Bench, Pune. गार्ा फ़ाइल / Guard File. 6. आदेशानुसार / BY ORDER,
// True Copy // धनजी सधचव / Private Secretary आयकर अपीलीय अधधकरण, पुणे / ITAT, Pune.
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Date 1 Draft dictated on 22.10.2021 Sr.PS/PS 2 Draft placed before author 25.10.2021 Sr.PS/PS 3 Draft proposed and placed JM/AM before the second Member 4 Draft discussed/approved by AM/JM second Member 5 Approved draft comes to the Sr.PS/PS Sr. PS/PS 6 Kept for pronouncement on Sr.PS/PS 7 Date of uploading of order Sr.PS/PS 8 File sent to Bench Clerk Sr.PS/PS 9 Date on which the file goes to the Head Clerk 10 Date on which file goes to the A.R 11 Date of dispatch of order