Ravikant Choudhry, CHENNAI V. JCIT, CHENNAI

ITA 1358/CHNY/2014

• Counselvise Citation: [2016] 131 COUNSELVISE.COM (IT) 7891 (ITAT-CHENNAI)
• Duration Of Justice: 2 year(s) 6 month(s) 30 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 14-12-2016
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: D
• Next Hearing Date: 28-11-2016
• Assessment Year: 2009-2010
• Appeal Filed On: 15-05-2014
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: A V SREEKANTH IRS
• Assessee Lawyers: M P SENTHIL KUMAR S
• Keywords: Capital asset; Gift; Earning of tax free income; Retrospective amendment; Cost of acquisition

Judgement Text

, , IN THE INCOME TAX APPELLATE TRIBUNAL D BENCH : CHENNAI . . . , !' . #$#% , & '' ( [BEFORE SHRI N.R.S. GANESAN, JUDICIAL MEMBER AND SHRI ABRAHAM P. GEORGE, ACCOUNTANT MEMBER ] ./I.T.A. NO. 1358/MDS/2014 / ASSESSMENT YEAR : 2009-2010. SHRI. RAVIKANT CHOUDHRY, NO.51, ELEPHANT GATE STREET, SOWCARPET, CHENNAI 600 079. VS. THE JOINT COMMISSIONER OF INCOME TAX, COMPANY CIRCLE I(1) CHENNAI 600 034. [PAN AAEPR 7102C] ( )* / APPELLANT) ( +,)* /RESPONDENT) / APPELLANT BY : SHRI. PHILIP GEORGE & M.P. SENTHIL KUMAR, ADVOCATES. /RESPONDENT BY : SHRI. A.V. SREEKANTH, IRS, JCIT. /DATE OF HEARING : 28-11-2016 ! /DATE OF PRONOUNCEMENT : 14-12-2016 / O R D E R PER ABRAHAM P. GEORGE, ACCOUNTANT MEMBER IN THIS APPEAL ASSESSEE HAS TAKEN ALTOGETHER FIV E GROUNDS OF WHICH GROUNDS NO.1, 4 & 5 ARE GENERAL IN NATURE NE EDING NO SPECIFIC ADJUDICATION. ITA NO. 1358/MDS/2014. :- 2 -: 2. VIDE ITS GROUND NO.2, ASSESSEE ASSAILS A DISALLOWAN CE OF C37,51,029/- MADE U/S.14A OF THE INCOME TAX ACT, 19 61 (IN SHORT THE ACT). 3. FACTS APROPOS ARE THAT ASSESSEE, A DEALER IN SHARE S AND SECURITIES HAD FILED HIS RETURN OF INCOME FOR THE I MPUGNED ASSESSMENT YEAR DISCLOSING INCOME OF C1,00,000/-. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, IT WAS NOTED BY THE LD. ASS ESSING OFFICER THAT ASSESSEE HAD CLAIMED DIVIDEND C37,06,691/- AS EXEMP T U/S.10(34) OF THE ACT. AS PER LD. ASSESSING OFFICER, ASSESSEE HAD NOT MADE ANY DISALLOWANCE BY ITSELF, FOR EXPENDITURE INCURRED IN EARNING SUCH INCOME. CLARIFICATION ON THE ISSUE WAS SOUGHT. THEREUPON ASSESSEE STATED THAT HE HAD NOT INCURRED ANY EXPENDITURE FOR EARNING THE ABOVE EXEMPTED INCOME. LD. ASSESSING OFFICER DID NOT ACCEPT THIS CONTENTION CITING FOLLOWING REASONS:- (I) ASSESSEE HAS CLAIMED INTEREST EXPENDITURE OF C27,43,099/- ON BORROWED CAPITAL DURING THE RELEVAN T PREVIOUS YEAR. ASSESSEE COULD NOT ESTABLISH THAT SUCH BORROWED FUNDS WERE NOT USED FOR MAKING TAX FREE INVESTMENTS. (II) CLAIM OF THE ASSESSEE THAT NO ROUTINE OR ADMINIST RATIVE EXPENDITURE WAS INCURRED FOR THE PURPOSE OF MAKING THE INVESTMENTS COULD NOT BE BELIEVED. (III) BY VIRTUE OF RULE 8D, IT WAS MANDATORY TO MAKE A DISALLOWANCE AGAINST EXEMPT INCOME CLAIMED BY THE ASSESSEE. ITA NO. 1358/MDS/2014. :- 3 -: DISALLOWANCE FOR INTEREST UNDER RULE 8D(2)(II) OF THE ACT CAME TO C23,11,516/- AND THAT FOR INDIRECT EXPENDITURE UND ER RULE 8D(2)(III) CAME TO C14,39,513/-, AGGREGATING TO C37,51,029/-. 4. AGGRIEVED, ASSESSEE MOVED IN APPEAL BEFORE LD. COMMISSIONER OF INCOME TAX (APPEALS). ARGUMENT OF THE ASSESSEE WAS THAT NO EXPENDITURE WAS INCURRED FOR EARNING TH E EXEMPT INCOME. AS PER ASSESSEE HE WAS HAVING SUFFICIENT CAPITAL AN D INTEREST FREE BORROWING FOR MAKING THE TAX FREE INVESTMENTS. FUR THER, ARGUMENT OF THE ASSESSEE WAS THAT DISALLOWANCE WORKED OUT U/S.1 4A OF THE ACT WAS MORE THAN THE TOTAL EXPENDITURE CHARGED IN ITS PRO FIT AND LOSS ACCOUNT. AS PER ASSESSEE DISALLOWANCE UNDER RULE 8D(2)(II) H AD TO BE CONFINED AT THE BEST TO THE NET INTEREST PAYMENT OF C10,18 ,544/- ONLY. ASSESSEE ALSO CONTENDED THAT NO EXPENDITURE FOR REM UNERATION TO ANY STAFF WAS INCURRED IN RELATION TO THE EXEMPT INCOM E. RELIANCE WAS PLACED ON THE JUDGMENT OF HONBLE DELHI HIGH COURT JUDGMENT IN THE CASE OF MAXOP INVESTMENT LTD VS. CIT (2012) 347 ITR 272 AND THAT OF HONBLE BOMBAY HIGH COURT IN THE CASE OF GODREJ AND BOYCE MFG. CO. LTD VS. DCIT (2010) 328 ITR 81 . 5. HOWEVER, LD. COMMISSIONER OF INCOME TAX (APPEALS) W AS NOT IMPRESSED BY THE ABOVE ARGUMENTS. AS PER LD. COMMIS SIONER OF ITA NO. 1358/MDS/2014. :- 4 -: INCOME TAX (APPEALS)M ASSESSEE HAD NOT MADE ANY DIS ALLOWANCE FOR EXPENDITURE RELATABLE TO THE EARNING OF THE EXEMPT INCOME. AS FOR THE CLAIM OF THE ASSESSEE THAT BORROWED MONEY WERE NOT USED FOR MAKING INVESTMENTS, LD. COMMISSIONER OF INCOME TAX (APPEAL S) RELYING ON JURISDICTIONAL HIGH COURT DECISION IN THE CASE OF BEACH MINERALS COMPANY P. LTD IN T.C. NO.681/2013, DATED 02.12.201 3 HELD THAT MERE AVAILABILITY OF FUNDS WOULD NOT BY ITSELF BE A GO OD EXPLANATION FOR TAX FREE INVESTMENTS, WHEN ASSESSEE HAD SUBSTANTIAL INT EREST BEARING BORROWED FUNDS. THOUGH, THE LD. COMMISSIONER OF IN COME TAX (APPEALS) NOTED THE JUDGMENT OF HONBLE BOMBAY HIG H COURT IN THE CASE OF CIT VS. RELIANCE UTILITIES AND POWER LTD 313 ITR 340, HE WAS OF THE OPINION THAT IN THE FACTS AND CIRCUMSTANCES OF THE CASE, THE PRINCIPLES LAID DOWN BY HONBLE MADRAS HIGH COURT IN BEACH MINERALS COMPANY (P) LTD (SUPRA) COULD BE BETTER APPLIED HER E. AS FOR THE CLAIM OF THE ASSESSEE THAT TOTAL DISALLOWANCE MADE BY TH E LD. ASSESSING OFFICER WAS MORE THAN INTEREST EXPENDITURE OF C27,4 3,099/- CHARGED IN THE PROFIT AND LOSS ACCOUNT, LD. COMMISSIONER OF IN COME TAX (APPEALS) OBSERVED THAT DISALLOWANCE MADE BY THE LD. ASSESSIN G OFFICER UNDER RULE 8D(II) CAME TO C23,11,516/- AND THE BALANCE D ISALLOWANCE WAS UNDER RULE 8D(III). AS FOR THE CLAIM OF THE ASSESS EE THAT ONLY NET INTEREST EXPENDITURE SHOULD BE CONSIDERED, LD. COMM ISSIONER OF INCOME TAX (APPEALS) OBSERVED THAT ASSESSEE COULD NOT CO-R ELATE THE INTEREST ITA NO. 1358/MDS/2014. :- 5 -: RECEIPTS AND INTEREST PAYMENT, FOR GIVING ANY SUCH ALLOWANCE. AS TO THE CLAIM OF THE ASSESSEE THAT HE HAD NOT INCURRED ANY INDIRECT EXPENDITURE, LD. COMMISSIONER OF INCOME TAX (APPEA LS) NOTED THAT EVEN THOUGH ASSESSEE WAS ONLY AN INDIVIDUAL, HE HAD MAINTAINED BOOKS OF ACCOUNTS AND WAS PREPARING PROFIT AND LOSS ACCO UNT AND BALANCE SHEET WHERE A LARGE NUMBER OF EXPENDITURE WAS DEBI TED. ACCORDING TO THE LD. COMMISSIONER OF INCOME TAX (APPEALS) ASS ESSEES CONTENTION THAT HE HAD NOT INCURRED ANY INDIRECT EXPENDITURE C OULD NOT BE ACCEPTED. THUS, HE CONFIRMED THE ORDER OF THE LD. ASSESSING OFFICER. 6. NOW BEFORE US, LD. AUTHORISED REPRESENTATIVE STRONG LY ASSAILING THE ORDERS OF THE LOWER AUTHORITIES SUBMI TTED THAT ASSESSEE HAD INTEREST FREE OWN FUNDS C23,06,12,317/- AT THE END OF THE RELEVANT PREVIOUS YEAR. ACCORDING TO HIM, OPENING BALANCE F ROM FUNDS OF CAPITAL FUNDS ALONE CAME TO C22,85,73,423/-. THUS , ACCORDING TO HIM, SUFFICIENT OWN FUNDS WERE AVAILABLE WITH THE ASSESS EE. ARGUMENT OF THE LD. AUTHORISED REPRESENTATIVE WAS THAT IN SUCH A SITUATION TAX FREE INVESTMENTS HAD TO BE DEEMED AN GOING OUT OF THE IN TEREST FREE FUNDS AND NOT FROM THE INTEREST BEARING LOAN FUNDS. FUR THER, AS PER LD. AUTHORISED REPRESENTATIVE ASSESSEE HAD SPECIFICALLY CLAIMED THAT HE HAD INCURRED NO EXPENDITURE FOR EARNING THE DIVIDEN D INCOME AND WITHOUT DEMONSTRATING THAT THIS CLAIM WAS INCORRECT , THE LD. ASSESSING ITA NO. 1358/MDS/2014. :- 6 -: OFFICER FELL IN ERROR IN MAKING A DISALLOWANCE UNDE R RULE 8D. LD. AUTHORISED REPRESENTATIVE ALSO SUBMITTED THAT RULE 8D WAS AMENDED BY A NOTIFICATION DATED 02.06.2016 WHEREBY 8D(2)(II I) STOOD OMITTED. ACCORDING TO HIM, MAXIMUM DISALLOWANCE UNDER RULE 8 D(2) WAS ONLY 1% OF THE AVERAGE VALUE OF THE INVESTMENTS, WHICH C OULD NEVER EXCEED THE TOTAL EXPENDITURE CLAIMED BY THE ASSESSEE. LD. AUTHORISED REPRESENTATIVE SUBMITTED THAT AMENDMENT OF RULES TH OUGH BROUGHT IN WITH EFFECT FROM 2 ND JUNE 2016 WAS INTENDED TO ALLEVIATE GENUINE HARDSHIP CAUSED TO ASSESSEES AND THEREFORE HAD TO B E GIVEN RETROSPECTIVE EFFECT. 7. PER CONTRA, LD. DEPARTMENTAL REPRESENTATIVE STRONG LY SUPPORTED THE ORDERS OF THE AUTHORITIES BELOW. 8. WE HAVE CONSIDERED THE RIVAL CONTENTIONS AND PERUS ED THE ORDERS OF THE AUTHORITIES BELOW. FIRST DEALING WITH THE CLAIM OF THE ASSESSEE THAT HE HAD SPECIFICALLY MENTIONED NOT INC URRING ANY EXPENDITURE FOR EARNING EXEMPT DIVIDEND INCOME, A C AREFUL VERIFICATION OF COMPUTATION OF TOTAL INCOME FILED BY THE ASSESSE E, PLACED AT PAPER BOOK PAGE 1 TO 3, SHOW THAT THERE WAS NOT EVEN A WH ISPER REGARD INCURRING OR NOT INCURRING ANY SUCH EXPENDITURE. IN OTHER WORDS, ASSESSEE IN ITS RETURN OF INCOME HAD NOT STATED THA T HE HAD INCURRED NO ITA NO. 1358/MDS/2014. :- 7 -: EXPENDITURE FOR EARNING DIVIDEND INCOME. CLAIM IF AT ALL MADE, WAS ONLY WHEN THIS WAS BROUGHT TO HIS NOTICE BY THE LD. ASSESSING OFFICER. THUS AT THE BEST, THE CLAIM THAT NO EXPENDITURE WAS INCURRED IN RELATION TO THE TAX FREE INVESTMENTS, CAN BE TREAT ED ONLY AS AN AFTER THOUGHT AND NOT A GENUINE ONE. ESPECIALLY SO, SINC E ASSESSEE WAS IN THE BUSINESS OF TRADING IN SHARES. ASSESSEES PROF IT AND LOSS ACCOUNT REFLECTS FOLLOWING EXPENDITURE INCURRED BY HIM IN RUNNING ITS SHARE TRADING AND INVESTMENT BUSINESS DURING THE RELEVANT PREVIOUS YEAR, APART FROM LOSS IN TRADING OF SHARES, SPECULATION L OSS AND LOSS FROM A CONCERN CALLED ARIHANT & COMPANY. TO AUDIT FEES : 7500.00 TO BANK CHARGES : 1515.00 TO DEMAT CHARGES : 26539.00 TO INTEREST, ADMINISTRATIVE & CUSTODY CHARGES : 4130959.00 TO INTEREST PAID : 2743099.00 TO PORT FOLIO MGNT FEE : 435717.00 TO DONATION : 10960.00 TO TRANSACTION CHARGES : 12996.00 TO INSURANCE : 10279.00 TO DEPARTMENT CHARGES : 3526.00 ---------------- 73,83,090.00 ----------------- ON THE FACE OF THE ABOVE, THE CLAIM OF THE ASSESSE E THAT HE HAD NOT INCURRED ANY EXPENDITURE FOR MAKING THE INVESTMEN TS EARNING HIM THE EXEMPT INCOME WAS IN OUR OPINION RIGHTLY REJECTED BY THE LOWER ITA NO. 1358/MDS/2014. :- 8 -: AUTHORITIES. COMING TO THE CLAIM OF THE ASSESSEE THAT INTEREST PAID BY IT WAS NOT RELATABLE TO EARNING OF TAX FREE INCOME , WHAT WE FIND IS THAT THE ONLY BUSINESS CARRIED ON BY THE ASSESSEE WAS T RADING IN SHARES. A LOOK AT BALANCE SHEET PLACED AT PAPER BOOK PAGE 17 SHOW THAT ALL EQUITY SHARES HELD WERE SHOWN UNDER THE INVESTMENTS PORTFOLIO. IN OTHER WORDS ASSESSEE HAD CREDITED THE PROFIT ARISI NG ON TRADING OF SHARES HELD BY HIM AS INVESTMENT IN HIS PROFIT AND LOSS ACCOUNT. WHAT THE ASSESSEE HELD AS INVESTMENT WAS NOTHING BUT ITS STOCK-IN-TRADE ONLY. THUS CLAIM OF THE ASSESSEE THAT BORROWED CAPI TAL WAS NOT UTILIZED FOR INVESTMENTS EARNING ITS INTEREST FREE DIVIDEND WAS ALSO, IN OUR OPINION RIGHTLY REJECTED BY THE LOWER AUTHORITIES. RULE 8D(2)(II) CLEARLY APPLIED. SIMILAR IS THE CASE OF INDIRECT EXPENDITUR E ALSO. FOR THE VERY SAME REASON, ASSESSEES CLAIM THAT HE HAD INCURRED NO INDIRECT EXPENDITURE WAS ALSO IN OUR OPINION RIGHTLY REJECTE D BY THE LOWER AUTHORITIES. 9. COMING TO THE CLAIM OF THE LD. AUTHORISED REPRESENT ATIVE THAT AMENDMENT TO RULE 8D(2) MADE THROUGH NOTIFICAT ION DATED 02.06.2016 HAS TO BE DEEMED RETROSPECTIVE, NOTHING OF THAT SORT IS MENTIONED IN SUCH NOTIFICATION. ON OTHER HAND, IT IS SPECIFICALLY MENTIONED THAT THE AMENDMENT WOULD COME INTO FORCE ON THE DATE OF PUBLICATION IN OFFICIAL GAZETTE. ARGUMENT OF THE L D. ITA NO. 1358/MDS/2014. :- 9 -: AUTHORISED REPRESENTATIVE IS THAT NOTIFICATION WAS ISSUED SO AS TO ALLEVIATE HARDSHIP CAUSE TO ASSESSEES. HOWEVER, H E WAS NOT ABLE TO DEMONSTRATE WHAT WAS THE EARLIER HARDSHIP, AND WHAT WAS ALLEVIATED THROUGH THE AMENDMENT. EVEN IF WE CONSIDER THE AM ENDED RULE U/S.8D(2) AND PROVISO THERETO WHICH STIPULATE THAT DISALLOWANCE SHALL NOT EXCEED THE TOTAL EXPENDITURE OF THE ASSESSEE, S UCH EXPENDITURE GIVEN AT PARA 8 ABOVE, CAME TO C73,83,090/-. THIS IS MUCH HIGHER THAN THE ACTUAL DISALLOWANCE C37,51,029/- BY THE LD . ASSESSING OFFICER. CLAIM FOR NETTING OF THE INTEREST WAS ALSO RIGHTLY DISALLOWED SINCE ASSESSEE COULD NOT SHOW ANY NEXUS BETWEEN THE INTER EST PAID AND INTEREST EARNED. THUS, WE DO NOT FIND ANY REASON TO INTERFERE WITH THE ORDERS OF THE LOWER AUTHORITIES ON THIS ISSUE. GROU ND NO.2 STANDS DISMISSED 10. IN HIS GROUND NO.3, ASSESSEE ASSAILS AN ADDITION O F C1,33,02,525/- MADE UNDER THE HEAD SHORT TERM CAPI TAL GAINS IN RELATION TO THE SALE OF 11.065 ACRES OF LAND AT S RIPERUMBUDUR. 11. FACTS APROPOS ARE THAT ASSESSEE HAD SOLD A PROPERTY MEASURING 11.345 ACRES AT SRIPERUMBUDUR FOR A TOTA L CONSIDERATION OF C1,93,30,000/-. AFTER SETTING OF COST OF C80,77,50 0/-, A NET SURPLUS OF C1,12,52,500/- WAS SHOWN BY THE ASSESSEE. THIS WAS CLAIMED AS ITA NO. 1358/MDS/2014. :- 10 -: EXEMPT. AS PER THE ASSESSEE THE LAND WHICH WAS S OLD WAS AGRICULTURAL IN NATURE AND WAS ACQUIRED BY HIM FR OM VARIOUS PARTIES THROUGH NINE DIFFERENT CONVEYANCE DEEDS ENTERED DUR ING THE PERIOD 08.11.2006 & 26.12.2006. CONTENTION OF THE ASSESSEE WAS THAT THE SALE WAS DONE BY WAY OF LETTER CUM RECEIPTS DURING THIS PERIOD. THOUGH ASSESSEE PRODUCED LETTER CUM RECEIPTS FROM T HE CONCERNED PARTIES, HE COULD NOT PRODUCE ANY REGISTERED SALE DEED, EXECUTED BY HIM IN FAVOUR OF THE PURCHASER. HOWEVER, ASSESSEE HAD EXECUTED A POWER OF ATTORNIES ON 11.04.2008 AND 30.06.2008 WI TH RESPECT TO THESE PROPERTIES. LD. ASSESSING OFFICER AFTER VERI FYING GENERAL POWER OF ATTORNIES WAS OF THE OPINION THAT THE NATURE OF THE ASSET WAS NOT AGRICULTURAL AND THE INTENTION OF THE ASSESSEE WAS TO DEVELOP THE PROPERTY TO A RESIDENTIAL COLONY. AS PER LD. ASSES SING OFFICER THE PROPERTY WAS LOCATED WITHIN 8 KMS OF THE TOWN OF S RIPERUMBUDUR WHERE THE POPULATION WAS MORE THAN TEN THOUSAND. R ELIANCE WAS PLACED BY THE LD. ASSESSING OFFICER ON THE CENSUS A BSTRACT 2001 PUBLISHED BY DIRECTORATE OF CENSUS OPERATIONS, TAMI L NADU. FURTHER, AS PER LD. ASSESSING OFFICER TIME DIFFERENCE BETWEE N PURCHASE AND SALE OF THE PROPERTY WAS ONLY TWO YEARS AND THIS PROVED THE NON AGRICULTURAL INTENTIONS OF THE ASSESSEE. LD. ASSESSING OFFICER ALSO REWORKED THE COST OF THE LAND. ACCORDING TO HIM, COST OF THE LAN D SOLD WAS ONLY ITA NO. 1358/MDS/2014. :- 11 -: C60,27,475/-. THE BALANCE OF THE SUM OF C1,33,02,52 5/- WAS CONSIDERED BY THE LD. ASSESSING OFFICER AS SHOR T TERM CAPITAL GAINS AND ADDITION MADE ACCORDINGLY. 12. IN ITS APPEAL BEFORE THE LD. COMMISSIONER OF INCOME TAX (APPEALS), CONTENTIONS TAKEN BY THE ASSESSEE REA D AS UNDER:- '#$%&'((&))*+,-./01,-,%*,%&%*2(.34%*-&2 556789 *43&-:;'<314.),.3*)=*+2-2.31+<,%&'--&--0&+, >&*3 ?@@AB?@@CD12& E F*)&G&&2-*))2*,&2@H6556?@@E*+2 3&<1-,&3&2 *- G:4.0&+,I:-6?5@J9,:?55@@5?@@E1+ ,%&:;;14& :; ,%& F./ K&<1-,3*3L F31(&3.0/.2.3L F* )& G&&22*,&2?J6556?@@E*+23&<1-,&3&2 *- G:4.0&+,I:6 ?E7E75?@@E 1+ ,%& :;;14& :; ,%& F./ K&<1-,3*3L F31(&3.0/.2.3*+2 ? 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