AI Insights
The case involves M/s. Sion Panvel Tollways Pvt. Ltd., which engaged in infrastructure development, specifically the improvement of Sion Panvel Special State Highway under a BOT scheme. The company received loans and invested the idle funds in fixed deposits, earning interest income. The Revenue challenged the deduction of interest expenditure on these borrowings against the interest income earned from the FDRs. The Tribunal examined whether the interest paid on borrowings could be deducted under section 57(iii) of the Income-tax Act, 1961, against the interest income offered under section 56. The Tribunal concluded that the two transactions were independent and not interlinked, thus denying the deduction.
Appeal Details
Counselvise Citation
[2022] 140 COUNSELVISE.COM (IT) 137501 (ITAT-PUNE)
Assessee PAN
Bench
Appeal Number
CRN Number
Duration Of Justice
15 year(s) 4 month(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
15-11-2022
Appeal Filed By
Department
Order Result
Allowed
Bench Allotted
B
Next Hearing Date
13-11-2022
Assessment Year
misc
Appeal Filed On
15-07-2007
Judgement Text
IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R.S. SYAL, VICE PRESIDENT AND SHRI PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER ITA Nos. 489 and 249/PUN/2018 नधा रण वष / Assessment Years : 2013-14 & 2014-15 ACIT, Circle-6, Pune Vs. M/s. Sion Panvel Tollways Pvt. Ltd., 35, IVRCL house, 35, Suyojna, C.H.F. Koregaon Park, Pune 411 001 PAN : AANCS4045D Appellant Respondent C.O. Nos. 48 & 49/PUN/2022 (Arising out of ITA Nos.489 & 249/PUN/2018 नधा रण वष / Assessment Years : 2013-14 & 2014-15 M/s. Sion Panvel Tollways Pvt. Ltd., 35, IVRCL house, 35, Suyojna, C.H.F. Koregaon Park, Pune 411 001 PAN : AANCS4045D Vs. ACIT, Circle-6, Pune Appellant Respondent आदेश / ORDER PER R.S. SYAL, VP : These two appeals by the Revenue and equal number of Cross Objections by the assessee pertain to the assessment years Assessee by Shri Rahul Hakani and Shri Shashi Bekal Revenue by Shri Sardar Singh Meena and Shri M.G. Jasnani Date of hearing 14-11-2022 Date of pronouncement 16-11-2022 M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 2 2013-14 & 2014-15. Since common issues and overlapping grounds are raised in these appeals and Cross Objections, we are, therefore, proceeding to dispose them off by this consolidated order for the sake of convenience. 2. There is a delay of 322 days in filing the cross objections by the assessee. An affidavit has been filed attributing the reasons to Covid-19 pandemic prevailing across the globe. We are satisfied with the reason so stated. Ergo, the delay is condoned by virtue of judgment of the Hon’ble Supreme Court in Cognizance for Extension of Limitation, In re 438 ITR 296 (SC) read with judgment in Cognizance for Extension of Limitation, In re 432 ITR 206 (SC) dated 08-03-2021 and 421 ITR 314 and the instant cross objections are admitted for disposal on merits. A.Y. 2013-14 : 3. The only issue raised by the Revenue through various grounds is against the granting of deduction of interest expenditure of Rs.6,82,57,053/- u/s 57 of the Income-tax Act, 1961 (hereinafter also called `the Act’) against the interest income earned from fixed deposits prior to commencement of business. The assessee in its Cross Objection pleads in alternate for treating M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 3 the interest income as capital receipt which would reduce the cost of the qualifying assets. 4. Pithily put, the factual panorama of the case is that the assessee is engaged in the business of infrastructure activities, principally, consisting of development of multiproduct and construction. The assessee received a contract from the Government of Maharashtra represented by Public Works Department for improvement of Sion Panvel Special State Highway under Build-Operate-Transfer (BOT) scheme. It is undisputed that the project was completed somewhere in September, 2014 relevant to assessment year 2015-16, that is, beyond the two years under consideration. In the immediately preceding year, the assessee obtained loan from banks amounting to Rs.351.43 crore in December, 2011 and purchased FDRs amounting to Rs.325.00 crore in January, 2012. For the year under consideration, the assessee earned interest on such bank deposits to the tune of Rs.4,91,20,726/-, which was declared as income under the head ‘Income from other sources’. The assessee calculated proportionate interest of Rs.6,82,57,053/- relatable to the borrowings used for making FDRs. Deduction for M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 4 such sum was claimed u/s. 57(iii) and the resultant loss of Rs.1.91 crore was claimed in the computation of total income. The Assessing Officer (AO) did not accept the grant of deduction of interest expenditure against the interest income earned from FDRs and held the interest of Rs.4,91,20,726/- as income chargeable under the head ‘Income from other sources’. The ld. CIT(A) overturned the assessment order by holding that such interest was deductible u/s.57(iii) because the assessee had utilized borrowed funds for investment in fixed deposits. Aggrieved thereby, the Revenue has come up in appeal before the Tribunal. 5. Having heard the rival submissions and gone through the relevant material on record, it is pertinent to note that the assessee did not commence the business during the year under consideration and also the next year as well. The assessee made certain borrowings from bank for the purpose of developing and improving Sion Panvel State Highway under BOT scheme. Since the amount borrowed was not immediately required for the improvement work, the assessee’s parked a larger chunk of such borrowing in the fixed deposits and earned interest thereon. The moot point for determination from the Revenue’s perspective is M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 5 whether the interest paid on borrowings can be allowed as deduction against the interest income earned. This pre-supposes, firstly, the taxability of interest on FDRs as income under the head “Income from other sources” u/s 56 as was also suo motu offered by the assessee and then the granting of deduction for interest expenditure u/s 57(iii). The assessee, apart from supporting the impugned order on this score, has also taken a stand that such interest income is not at all an item of income u/s 56, which should be reduced from the cost of assets for which the borrowing was made. We will examine both the issues independently hereinafter. 6. First is about the granting of deduction by the ld. CIT(A) of the interest expenditure u/s 57(iii) against the interest income offered u/s 56. Section 57(iii) of the Act stipulates for allowing deduction of “any other expenditure (not being in the nature of capital) laid down or expended wholly and exclusively for the purpose of making or earning such income”. It is vivid from the mandate of the provision that only such expenditure can be allowed as deduction which is incurred wholly and exclusively for the purpose of earning such income. In the present context, only M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 6 such expenditure will qualify for deduction which has been incurred for earning interest income on FDRs. When we examine the factual matrix under consideration, it becomes explicitly clear that the funds were borrowed by the assessee for the purpose of development of Sion Panvel State Highway, on which interest was paid. After making the borrowings, the assessee made FDRs out of such funds. The interest paid on borrowings for highway development activity cannot be considered as expenditure incurred for the purpose of earning interest income notwithstanding the fact that the idle funds were utilized for making FDRs. The prescription of the provision for granting deduction is that the expenditure should be incurred wholly and exclusively for the purpose of earning income. Inter-twining of funds between the borrowing for highway development before commencement of business and purchasing of the FDRs is though a relevant factor but not conclusive. The decisive criterion for allowing the deduction is that the two transactions - of earning income and incurring expenditure - should have an interwoven activity or at least common connection in some manner apart from mere utilization of funds from one into the other. To put it M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 7 simply, the activity of earning income should be directly connected with or be incidental to the primary activity for which borrowing was made. If the transactions involving activities of earning income and incurring expenditure are not even distantly related to each other, then deduction u/s 57(iii) fails. We are confronted with a situation in which the borrowing was made for developing highway. The FDRs were purchased for utilization of idle funds. Such FDRs were not required to be made as a condition precedent for having letter of credit or furnishing of guarantee for doing any activity connected with the highway development. In such circumstances, it becomes glaring that the proportionate interest expenditure on borrowing for highway development has no relation with the making of FDRs on which the interest income chargeable to tax under the head `Income from other sources’ was earned. 7. The Hon’ble jurisdictional High Court in CIT Vs. United Wire Ropes Ltd. (1980) 121 ITR 762 (Bom.) considered almost similar facts in a case in which the assessee received interest on the amounts kept in short term deposits with various banks which was assessed as ‘Income from other sources’. The assessee paid M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 8 interest in respect of loan which it had obtained. Deduction of interest paid on loan exceeded the interest received and hence, nothing was offered for taxation. The AO did not accept the assessee’s contention. When the matter finally came before the Hon’ble High Court, it was held that the interest paid on loan could not be set off under s. 57(iii) against interest earned on deposits, in the absence of any evidence that the two transactions were so integrated as to be regarded a single composite transaction. In the hue of the above discussion and the binding precedent, we hold that the ld. CIT(A) was not justified in allowing deduction of proportionate interest on borrowing u/s 57(iii) against the interest income earned on FDRs, which was offered by the assessee as chargeable to tax u/s 56 of the Act. The impugned order is overturned on this score. 8. Now, we espouse the point canvassed by the assessee in its cross objection that the interest income earned on FDRs is a ‘capital receipt’ not chargeable to tax which would reduce the highway development costs including the interest expenditure etc. It is thus seen that the assessee has recorded a shift from its original stand of deduction of interest paid under section 57(iii) M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 9 against interest earned on FDRs offered as taxable u/s 56 to now treating interest earned as not an income itself under section 56 and consequently claiming set off of such interest income against the interest expenditure and other capital expenditure incurred for which the loan was taken. 9. We are not convinced with the alternate submission of the assessee. It cannot be said that no income chargeable to tax can be earned simply because the business has not commenced. There are five heads of income mutually exclusive of each other. If a particular income has been earned by a businessman before the commencement of business, which is otherwise chargeable to tax under one of heads, the same will be taxed under such head notwithstanding the fact that there is no income under the head `Profits and gains of business or profession’ for non- commencement of business. The Hon’ble Supreme Court in Tuticorin Alkali Chemicals & Fertilizers Ltd. Vs. CIT (1997) 227 ITR 172 (SC) considered similar circumstances as are extantly obtaining. In that case also, the assessee invested the funds borrowed for the purpose of setting up factories in short term deposits with the bank and earned interest thereon during M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 10 construction and establishment of its factory. Interest income was initially offered for taxation as `Income from other sources’ and set off was claimed against the business loss. Later on, a revised return was filed claiming that interest expenditure was required to be capitalized and hence the interest income was not exigible to tax as it would reduce prior period expenses. The AO as well as the Tribunal rejected the assessee’s contention. When the matter finally came before the Hon’ble Supreme Court, their Lordships held that: “The company may also, as in this case, keep the surplus fund in short-term deposits in order to earn interest. Such interest will be chargeable u/s.56”. To similar effect is the judgment of the Hon’ble Apex Court in CIT Vs. Autokast Ltd. (2001) 248 ITR 110 (SC) laying down that Interest earned on short-term deposit of amount borrowed for setting up business is assessable to tax in the hands of assessee as income from other sources. 10. Reliance of the ld. AR on CIT Vs. Bokaro Steel Ltd. (1999) 236 ITR 315 (SC) is misplaced. In that case, the assessee, prior to commencement of business and during the construction and erection phase, charged rent from its contractors for housing of M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 11 their workers engaged in construction of assessee’s factory and also earned interest on advances made to contractors. This amount was claimed as capital receipt, which got countenanced by the Hon’ble Apex Court. The distinguishing point to be noted is that in that case that the contractors who were constructing the assessee’s factory were given certain advances for the purpose of constructing the factory, on which interest was earned. Such interest income was held to be directly connected with or incidental to the construction work. There cannot be any dispute about the deductibility of interest in such circumstances from the cost of construction. However, in the instant case, the receipt of interest on FDRs has no relation whatsoever with the business of the assessee much less with the improvement of State Highway and both the transactions are independent of each other. 11. The ld. AR also relied on the judgment of the Hon’ble Supreme Court in CIT Vs. Shree Rama Multi Tech Ltd. (2018) 403 ITR 426 (SC) for canvassing a view that interest income should be adjusted against the capital costs for developing highway. In that case, the assessee came out with a public issue and certain share application money was received which was M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 12 deposited with the bank on which interest was earned. The assessee contended for set off of interest income against the public issue expenses. The Hon’ble Supreme Court accorded its imprimatur to allowing set off of interest income against the public issue expenses. Again, the reason for allowing such set off was that the share application money received by the assessee was required to be statutorily deposited in bank account. Since the shares related to capital structure of the company for which certain expenses were incurred, the interest income on such amount, required to be statutorily deposited with the bank, was held to be adjustable against share issue expenses. Au contraire, we are concerned with a situation in which the assessee was not supposed to statutorily keep the amount in FDRs. Rather the loan was obtained for improvement of the highway. It was only during the interregnum that the borrowed amount was deposited in the FDRs on which interest was earned. There is no correlation whatsoever between the transaction of borrowing the sums from the banks and the making of FDRs. The assessee, at its sweet will, parked the borrowed amount in the FDRs and earned interest thereon. M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 13 12. One needs to draw a line of distinction between the cases in which the transaction resulting into income is connected with the other activity for which capital was borrowed on which interest is paid. If the connection is established between the two, then such income qualifies for set off. Like the case of Bokaro (supra), in which rent and interest received from contractors was connected with the construction activity and in the case of Shree Rama Multi Tech (supra), in which FDRs were statutorily required to be made for issuing share capital. It is in such circumstances that the income cannot be taxed as such but reduces the cost incurred. If no connection is established between the income and expenditure, then such income is required to be taxed separately. Like the case of Tuticorin (supra) and Autokast (supra), in which interest was earned from the deposit of idle funds and the making of FDRs had no relation with the purpose for which the loan was taken. Such a distinction can be more appropriately appreciated with the judgment of the Hon’ble Supreme Court in Bongaigaon Refinery & Petrochemicals Ltd. Vs. CIT (2001) 251 ITR 329 (SC), in which the assessee derived income towards charges for equipment and recoveries from the contractors on account of water and M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 14 electricity supply during the formation period and also earned interest income from deposits prior to commencement of the business. It was held that the first set of items were not chargeable to tax and would be adjusted against the project cost. However, Interest income was held to be separately taxable. The case under consideration falls in the category of Tuticorin (supra) and Autokast (supra) in which no relation of the interest income has been proved with the activity of improving highways for which the loan was taken. We thus hold, that the interest earned by the assessee is chargeable to tax under the head ‘Income from other sources’ and cannot be allowed set off against the capital work-in- progress. 13. Having held that the assessee is not entitled to set off of interest paid amounting to Rs.6.82 crore against the interest income, and further that interest income of Rs.4.91 crore is chargeable to tax separately, the logical consequence of this is that the interest cost of Rs.6.82 crore would go to increase the amount of capital work-in-progress in the same way as has been the interest paid on bank borrowings not used for purchasing FDRs. To clarify, if, for example, an assessee borrows a sum of M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 15 Rs.100/- for construction on which interest of Rs.10/- is incurred. Further suppose a sum of Rs.80/- out of such borrowing is utilised for making FDRs which is unconnected with the construction. Total interest of Rs.10/- payable by the assessee on the borrowings is liable to be capitalised. Proceeding with the hypothetical example, the assessee capitalized Rs.2 and claimed deduction of Rs.8 against the interest income. Once it is held that Rs.8 cannot be allowed deduction against interest income, then such interest of Rs.8 will also get the same treatment of capitalization as has been given to Rs.2. In other words, the entire interest of Rs.10 on borrowing will be capitalized. We order accordingly. 14. In the result, the appeal of the Revenue is allowed and the cross objection of the assessee is dismissed. A.Y. 2014-15 15. The Revenue is aggrieved in the same way against the deletion of addition of interest expenditure against interest income which was taxed as ‘Income from other sources’. The assessee in its cross objection has pitched for set off of interest income against the other pre-operative costs including interest M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 16 expenditure on borrowings. Both the sides are consensus ad idem that the facts and circumstances of this issue are similar to those of the immediately preceding year. The ld. DR, referring to the relevant portions of the assessment order, submitted that the assessee categorically admitted before the AO that the borrowings made for the purpose of improvement of the highway were utilized for the purpose of making the FDRs. This fact is otherwise also apparent from the facts noted for the preceding year. Following the view taken hereinabove, we overturn the impugned order on this score and hold that the interest income earned on FDRs is chargeable to tax as `Income from other sources’ without any deduction of interest expenditure. Further, such interest income will not be set off against the interest expenditure on borrowings or other pre-operative expenses. However, such interest expenditure would increase the amount of capital work-in-progress. The respective grounds raised by the Revenue in its appeal are allowed and by the assessee in its cross objection are dismissed. 16. The only other issue which survives in the appeal of the Revenue is against the deletion of addition of Rs.3,74,11,321/- M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 17 made by the AO u/s.56(2)(viib) of the Act by accepting the value of shares at Rs.2412 as fair market value (FMV). 17. The facts anent to this issue are that the assessee issued 7,23,486 optionally Convertible Preference Shares (OCPS) with a face value of Rs.10/- each at premium of Rs.1,990/-. It received share premium of Rs.143.97 crore during the year which was claimed as not chargeable to tax. The OCPS were redeemable at a premium of Rs.1,990/- at any time on the option of the investors. The AO called upon the assessee to submit the details regarding valuation of the shares at the FMV. The assessee submitted that the FMV of unquoted equity shares of the company was determined as per Discounted Cash Flow (DCF) method. A Project Appraisal and Information Memorandum prepared by IDFC Capital Ltd., acting in its capacity as placement and distribution agent for the debt facilities of the assessee, was submitted calculating the FMV of the shares at Rs.2,412/- per share. The assessee contended that it received share premium only at Rs.1,990/- per share. The AO computed FMV as per Rule 11UA at Rs.1938.29. The differential amount of Rs.51.71 (Rs.1990 - Rs.1938.29) was multiplied with 7,32,486 number of M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 18 preferential shares issued to make the addition of Rs.3,74,11,321/- u/s.56(2)(viib) of the Act. The ld. CIT(A) deleted the addition. 18. Section 56(2)(viib) provides that where a company receives any consideration for issue of shares which exceeds its face value, aggregate consideration received which exceeds the FMV of the shares, shall be taken as income from other sources. The term “Fair Market Value” has been defined in Explanation (a) to the section, which talks of the fair market value of the shares to be determined in accordance with the method as may be prescribed. The relevant prescription is rule 11UA. Clause (c) of Rule 11UA(1) deals with the valuation of shares and securities to be taken as FMV that it would fetch if sold in the open market on the valuation date. Clause (b) of Rule 11UA(1)(c) deals with valuation of unquoted equity shares on the basis of Net Asset Value (NAV) method. Since the assessee company was recently incorporated and had not acquired any tangible assets, the NAV method cannot be applied. Turning to Rule 11UA(1)(c)(c), it provides for determining the FMV that it would fetch if sold in the open market. The assessee, in the instant case, has determined the FMV on the basis of Discounted Cash Flow method, which is M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 19 one of the accepted methods of valuation of shares. Considering the fact that the project of improving highways itself was at incomplete phase, it is this method which can be more appropriately applied vis-à-vis the NAV method. The assessee submitted a report prepared by IDFC Capital Ltd. valuing the shares under the Discounted Cash Flow method at Rs.2,412/- per share. The AO in the instant case did not find out anything amiss in the report, but simply went ahead by considering the FMV at Rs.1,990/- under Rule 11UA. 19. At this stage, a useful reference can be made to the judgment of the Hon’ble jurisdictional High Court in Vodafone M-Pesa Limited Vs. PCIT (2018) 256 Taxman 240 (Bom.). In that case, the AO raised the demand by changing method of valuation of shares issued at premium from the Discounted Cash Flow to Net Asset Value (NAV) method. The Hon’ble High Court, ruling in favour of the assessee, held that “the AO is undoubtedly entitled to scrutinize the valuation report and determine a fresh valuation either by himself or by calling for a final determination from an independent valuer to confront the petitioner. However, the basis has to be the Discounted Cash Flow method and it is not open to M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 20 him to change the method of valuation which has been opted for by the assessee”. Adverting to the facts of the instant case, it is seen that the assessee adopted the DCF method and determined the valuation of share at Rs.2,412/-. As against that the shares were issued only at premium of Rs.1,990/-. Since the AO has not found out any flaw in the calculation done by the IDFC Capital Limited under DCF method, the same has to be accepted. We, therefore, affirm the view taken by the ld. CIT(A) on this score. 20. In the result, the appeal of the Revenue is partly allowed and the cross objection by the assessee is dismissed. Order pronounced in the Open Court on 16 th November, 2022. Sd/- Sd/- (PARTHA SARATHI CHAUDHURY) (R.S.SYAL) JUDICIAL MEMBER VICE PRESIDENT प ु णे Pune; दनांक Dated : 16 th November, 2022 Satish M/s. Sion Panvel Tollways Pvt. Ltd., A.Yrs. 2013-14 & 2014-15 21 आदेश क त ल प अ े षत/Copy of the Order is forwarded to: 1. अपीलाथ / The Appellant; 2. यथ / The Respondent; 3. 4. 5. The CIT(A)-13, Pune The Pr.CIT-5, Pune िवभागीय ितिनिध, आयकर अपीलीय अिधकरण, पुणे “B” / DR ‘B’, ITAT, Pune 6. गाड फाईल / Guard file आदेशान ु सार/ BY ORDER, // True Copy // Senior Private Secretary आयकर अपीलीय अिधकरण ,पुणे / ITAT, Pune Date 1. Draft dictated on 14-11-2022 Sr.PS 2. Draft placed before author 16-11-2022 Sr.PS 3. Draft proposed & placed before the second member JM 4. Draft discussed/approved by Second Member. JM 5. Approved Draft comes to the Sr.PS/PS Sr.PS 6. Kept for pronouncement on Sr.PS 7. Date of uploading order Sr.PS 8. File sent to the Bench Clerk Sr.PS 9. Date on which file goes to the Head Clerk 10. Date on which file goes to the A.R. 11. Date of dispatch of Order. *
Other Referred Cases
Cognizance for Extension of Limitation, In re 438 ITR 296 (SC), Cognizance for Extension of Limitation, In re 432 ITR 206 (SC), CIT Vs. United Wire Ropes Ltd. (1980) 121 ITR 762 (Bom.), Tuticorin Alkali Chemicals & Fertilizers Ltd. Vs. CIT (1997) 227 ITR 172 (SC), CIT Vs. Autokast Ltd. (2001) 248 ITR 110 (SC), Bongaigaon Refinery & Petrochemicals Ltd. Vs. CIT (2001) 251 ITR 329 (SC), Vodafone M-Pesa Limited Vs. PCIT (2018) 256 Taxman 240 (Bom.)
Laws Referred To
Income-tax Act, 1961
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1:1 Consultation on Startup Compliance
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1:1 Consultation on Tax Litigation
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Shipping and Logistics Agreement
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Letter of Indemnity - Registering as Representative Assessee for Deceased
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