AI Insights
The case involves an appeal by the Revenue against the order of the Ld. CIT(A)-5, Ludhiana, which pertained to the assessment year 2017-18. The primary issue was the disallowance under section 14A read with rule 8D of the Income Tax Act, concerning expenses related to investments from which no taxable income was earned. The AO had made a disallowance of Rs. 67,47,703, which was contested by the assessee, M/s Aarti International Ltd., on the grounds that the disallowance should not exceed the exempt income earned, which was only Rs. 6,947. The Ld. CIT(A) agreed with the assessee, reducing the disallowance to the extent of the exempt income. The Revenue appealed against this decision, arguing that the CIT(A) had implicitly held the CBDT Circular No. 5/2014 to be illegal, which was not within the jurisdiction of the CIT(A). However, the Tribunal dismissed the appeal due to the low tax effect, as per the CBDT Circular No. 17/2019.
Appeal Details
Counselvise Citation
[2023] 140 COUNSELVISE.COM (IT) 127717 (ITAT-CHANDIGARH)
Assessee PAN
Bench
Appeal Number
CRN Number
Duration Of Justice
8 month(s) 6 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
27-03-2023
Appeal Filed By
Department
Order Result
Dismissed
Bench Allotted
A
Next Hearing Date
16-03-2023
Assessment Year
2017-2018
Appeal Filed On
21-07-2022
Judgement Text
आयकर अपील य अ धकरण,च डीगढ़ यायपीठ “ए” , च डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, CHANDIGARH ीमती दवा संह, या"यक सद#य एवं ी $व%म संह यादव, लेखा सद#य BEFORE: SMT. DIVA SINGH, JM & SHRI. VIKRAM SINGH YADAV, AM ITA NO.562/Chd/2022 Assessment Year : 2017-18 The DCIT Central Circle-1, Ludhiana M/s Aarti International Ltd. Aarti Complex, G.T. Road, Millerganj Ludhiana-141001 PAN NO: AABCA4454C Appellant Respondent ! " Assessee by : None (Written Submissions) # ! " Revenue by : Shri Manveet Singh Sehgal, Sr. DR $ % ! & Date of Hearing : 17/03/2023 '()* ! & Date of Pronouncement : 28/03/2023 आदेश/Order PER VIKRAM SINGH YADAV, A.M. : This is an appeal filed by the Revenue against the order of the Ld. CIT(A)- 5, Ludhiana dt. 30/05/2022 pertaining to A.Y. 2017-18 wherein the Revenue has taken the following grounds of appeal: 1. “Whether on the facts and in the circumstances of the case, the Ld. CIT(A) is justified in holding that disallowance u/s 14A of the Act will not exceed the total tax exempt income earned by the assessee, thereby implicitly holding CBDT Circular No. 5/2014 dated 11.02.2014 to be illegal whereas Circular No.5 of 2014 propounds that section 14A is triggered for disallowance of expenditure incurred which is relatable to tax exempt income even though no tax exempt income under the Act has been earned during a particular year? 2. Whether on the facts and in the circumstances of the case, the Ld. CIT(A) erred in ignoring the amendment made by the Finance Act, 2022 thereby inserting an explanation below section 14A which is read as under: Explanation: For the removal of doubts it is hereby clarified that notwithstanding anything to the contrary contained in this Act, the provisions of this section shall apply and shall be deemed to have always applied in a case where the income, not forming part of the total income under this Act, has not accrued or arisen or 2 has not been received during the previous year relevant to any assessment year and the expenditure has been incurred during the said previous year in relation to such income not forming part of the total income. 3. Whether on the facts and in the circumstances of the case, the decision of Ld. CIT(A) is against the law as per amendment made by the Finance Act, 2022 and interpreted by the Hon'ble Income-Tax Appellate Tribunal, Guwahati Bench in the case of ACIT, Circle-3, Guwahati Vs. Williamson Financial Services Limited in ITA Nos. 154 to 156/Gau/2019 dated 06.07.2022. 4. The appellant craves leave to add, amend, modify, vary, omit or substitute any of the aforesaid grounds of appeal at any time before or at the time of hearing of the appeal.” 2. Brief facts of the case are that the assessee company filed its return of income declaring total income of Rs. 34,04,30,510/-. Subsequently, the case was selected for complete scrutiny under CASS and thereafter notices under section 143(2) and 142(1) were issued alongwith detailed questionnaire. During the course of assessment proceedings, the AO issued a specific show cause stating that as per the assessee company’s balance Sheet, the investment made on first day of previous year i.e; 01/04/2016 is Rs. 62,87,35,853/- and on the last day of previous year i.e; 31/03/2017 is Rs. 72,08,04,911/- income from which does not or shall not form part of total income. Further it was stated that the assessee has incurred and claimed interest expenditure of Rs. 22,40,68,440/- and the expenditure incurred in relation to the investment is required to be added back to the income of the assessee and a show cause was issued as to why disallowance of Rs. 67,47,703/- under section 14A r.w.r 8D should not be made of expenses in relation to investments from which the income arises or may arise. 3. In response to the show cause, it was submitted by the assessee company that the investment in shares and mutual funds were made from its internal accrual and no money was borrowed for making the said investment. It was accordingly submitted that no disallowance is called for under section 14A read with rule 8D(2)(ii) of the Act. 3 3.1 It was further submitted that as regard disallowance under rule 8D(2)(iii), the assessee company has already disallowed a sum of Rs. 2265/- being 1% of the average income on which the exempt income was received while filing its return of income and therefore no further disallowance under section 14A was called for. 4. The submissions so filed by the assessee company were considered but not found acceptable. As per the AO, there was mixed use of interest bearing funds and it is not possible to link the borrowed funds with any particular income and therefore, only logical inference is that the claim of the assessee company that no borrowed funds were used cannot be accepted and therefore the AO recorded his satisfaction that the expenditure in relation to investment needs to be disallowed in terms of method prescribed under Rule 8D of the Income Tax Rules. The AO also referred to the CBDT Circular No. 05/2014 wherein it was mentioned that it is not material whether the exempt income is earned or not. The assessee has to suffer disallowance on investments from which the exempt income arises or can arise in future. It was held by the AO that the circular issued by the CBDT is binding on him as has been held by the judicial authorities all over the country, including by the Hon’ble Supreme Court stating that the circulars issued by the Board are binding on the Department. It was held by the AO that so far as the Department is concerned, whatever action it has to take, the same will have to be consistent with the circular which is in force at the relevant pint in time. Thereafter, the AO worked out the disallowance as per amended Rule 8D(ii) being equal to 1% of the annual average value of the investment amounting to Rs. 67,47,70, 382/- amounting to Rs. 67,47,703/- 5. Being aggrieved, the assessee carried the matter in appeal before the Ld. CIT(A). It was submitted that the AO has made the disallowance under section 14A r/w Rule 8D by taking the average of all the investments as on the first day of the previous year and on the last day of the previous year and has worked 4 out the disallowance @ 1% of the average value of the investment. However as per the amended Rule 8D(ii), an amount equal to 1% of the annual average of monthly average value of opening and closing balances of value of investments whose income is exempt is to be disallowed. It was submitted that during the course of assessment proceedings, the assessee has filed detailed submissions and had given monthly averages of the investments on which dividend income was earned and the disallowance of Rs. 2265/- was already made while filing the return of income and which has however been ignored by the AO. It was further submitted that during the year under consideration, the assessee has earned dividend income of Rs. 6,947/- and if at all, any further disallowance is to be made, the same would not exceed the exempt income. 6. During the course of appellate proceedings, the Ld. CIT(A) called for a remand report from the AO wherein the AO has confirmed that as per the computation of income, the assessee has claimed the exempt income under the head “dividend income” amounting to Rs. 6,947/-. The Ld. CIT(A) thereafter referred to the decision of Coordinate Bench in case of M/s Aarti Steels Ltd. in ITA No. 1522/Chd/2017 and Ld. CIT(A) order in assessee’s own case for A.Y. 2016- 17 and held that the disallowance under section 14A is required to be restricted to the extent of exempt income and the AO was directed to restrict the disallowance to the extent of exempt income after going through the returns/assessment records of the assessee. 7. Against the said findings and the directions of the Ld. CIT(A), the Revenue is in appeal before us. 7.1 During the course of hearing, the Ld. DR submitted that though the tax effect involved in this case is below the limit prescribed by CBDT Circular No. 17/2019 dt. 08/08/2019 read with CBDT Circular No. 03/2018 dt. 11/07/2018, however the case falls in the exception provided under para10(b) of the said Circular. It was accordingly submitted that the appeal filed by the Revenue 5 therefore deserve to be heard on merits. In this regard, it was submitted that the Ld. CIT(A) was not justified in holding that the disallowance under section 14A will not exceed the total tax exempt income earned by the assessee thereby implicitly holding CBDT Circular No. 5/2014 dt. 11/02/2014 to be illegal. 7.2 It was further submitted that the Ld. CIT(A) has ignored the amendment brought in by the Finance Act, 2022 wherein an explanation has been inserted to Section 14A wherein it has been clarified that the provisions of this section shall apply and shall be deemed to have always applied in a case where the income not forming part of the total income has not accrued or arisen or has not been received during the previous year and the expenditure has been incurred during the said previous year in relation to such income not forming part of the total income. It was accordingly submitted that the decision of the Ld. CIT(A) is against the law as per the amendment made by the Finance Act, 2022 and also interpreted by the Coordinate Guwahati Bench in case of ACIT Vs. Williamson Financial Services Limited in ITA Nos. 154 to 156/Gau/2019 dt. 06/07/2022. 8. None appeared on behalf of the assessee, however written submissions dated 15/02/2023 was received from Shri Subhash Aggarwal, Advocate on behalf of the assessee and it was submitted that the written submissions so filed on behalf of the assessee may be considered while disposing off the present appeal filed by the Revenue. 8.1 It was submitted that the assessee had earned dividend income of Rs. 6,947/- and as per Rule 8D, the disallowance comes to Rs. 2,265/- which has been suo-moto made by the assessee in its return of income. However, the AO has gone ahead and made disallowance of Rs. 67,47,703/- and which has been rightly sustained to the extent of exempt income amounting to Rs. 6,947/- by the ld CIT(A). 6 8.2. It was further submitted that the tax effect involved in the present appeal is below the threshold limit prescribed by the CBDT Circular No. 17/2019 dt. 08/08/2019 and therefore the appeal so filed by the Revenue deserves to be dismissed. 8.3. It was submitted that the regarding the CBDT Circular No. 5/2014 dt. 11/02/2014, the CBDT Circular is not binding on the appellate authorities and the Courts and it can only be binding on the departmental authorities as held by the Hon’ble Supreme Court in case of Navnit Lal C. Javeri 56 ITR 198 and UCO Bank 237 ITR 887. It was submitted that the Circular cannot over-ride the express provisions of Section 14 r.w.r 8D and it is for this reasons that the Ld. CIT(A) did not deal with the said Circular and merely not dealing with the said circular, it cannot be held that the ld CIT(A) has held the said circular to be illegal and therefore, the present matter doesn’t fall under exception 10(b) and the appeal of the Revenue deserve to be dismissed on account of low tax effect. 8.4 It was further submitted that the decision of Coordinate Guwahati Benches in case of ACIT Vs. Williamson Financial Services ltd. (supra) is not good law in view of the latest decision of Hon’ble Delhi High Court in case of Pr. CIT Vs. ERA Infrastructure (India) Ltd. dt. 20/07/2022 in ITA No. 204/2022 wherein the relevant findings reads as under: “8. Consequently, this Court is of the view that the amendment of Section 14A(by the Finance Act 2022), which is ""for removal of doubts" cannot be presumed to be retrospective even where such language is used, if it alters or changes the law as it earlier stood. 9. Though the judgment of this Court has been challenged and is pending adjudication before the Supreme Court, yet there is no stay of the said judgment till date. Consequently, in view of the judgments passed by the Supreme Court in Kunhayammed and Others vs. State of Kerala and Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association CSI Cinod Secretariat, Madras (1992) 3 SCC 1, the present appeal is dismissed being covered by the judgment passed by the learned predecessor Division Bench in PCIT vs. JL & FS Energy Development Company Ltd (supra) and Chem invest Limited vs. Commissioner of Income Tax-VI, (2015) 378ITR 33. 7 10. Accordingly, the appeal and application are dismissed. However, it is clarified that the order passed in the present appeal shall abide by the final decision of the Supreme Court in the SLP filed in the ease of PCIT vs. IL & FS Energy Development Company Ltd (supra).” 9. We have heard the ld DR and perused the material available on the record. On going through the CBDT Circular No. 3 of 2018 (supra) and in particular Para 10 of the said Circular, the contents thereof read as under: “10. Adverse judgments relating to the following issues should be contested on merits notwithstanding that the tax effect entailed is less than the monetary limits specified in para 3 above or there is no tax effect: (a) Where the Constitutional validity of the provisions of an Act or Rule is under challenge, or (b) Where Board's order, Notification, Instruction or Circular has been held to be illegal or ultra vires, or (c) Where Revenue Audit objection in the case has been accepted by the Department, or (d) Where the addition relates to undisclosed foreign assets/ bank accounts.” 9.1. We therefore find that the exception so carved in para 10(b) talks about a situation where the Board's order, Notification, Instruction or Circular has been held to be illegal or ultra vires. In the instant case, the AO has made a disallowance under Section 14A amounting to Rs 67,47,703/- relying on the CBDT Circular no. 5 of 2014 holding that the disallowance under section 14A becomes mandatory once any investment relating to earning of exempt income is made by the assessee and whether there is earning of any exempt income or not is immaterial before invoking the said provisions. The ld CIT(A) has restricted the said disallowance to the extent of exempt income of Rs 6947/- following the decisions of the Coordinate Bench in case of M/s Aarti Steel Ltd as well as his decision of the ld CIT(A) in assessee’s own case for A.Y 2016-17. We therefore find that the ld CIT(A) has followed the judicial discipline of following the decision of the jurisdictional tribunal as well as followed the principle of consistency in following the earlier decision of the ld CIT(A) in assessee’s own case rather than following the CBDT Circular no. 5 of 2014. However, the ld CIT(A) has not recorded any findings holding the CBDT Circular as illegal or ultra vires. In fact, the ld CIT(A) doesn’t have the jurisdiction to challenge the vires of the CBDT Circular. Being the appellate authority, he may not have followed the CBDT Circular and for valid reasons given that there are jurisdictional Tribunal 8 decision, however, not following the CBDT Circular cannot be held by any stretch of imagination as challenging the vires of the CBDT Circular or for that matter, holding it as illegal. In view of the same, we find that the present case clearly doesn’t fall under the exception 10(b) of the CBDT’s Circular No. 3 of 2018 as so contended by the ld DR before us and we are unable to accede to the said prayer so made on behalf of the Revenue and given that the tax effect involved is Rs. 23,35,244/- which is below the prescribed threshold of filing appeal before the Tribunal, we are of the considered view that the appeal so filed by the Revenue deserve to be dismissed on account of low tax effect. 9.2 Our view is fortified by the decision of Hon’ble Punjab & Haryana High Court in case of Pr. CIT-1 Vs. Sukhwant Singh (in ITA No. 283 of 2019 dt. 20/02/2020) wherein an identical matter relating to the appeal filed by the Revenue as to whether it falls under exception carved out under para 10(b) of CBDT Circular No. 3 of 2018 was under consideration and the Hon’ble High Court has dismissed the appeal filed by the Revenue holding that even the Tribunal has no jurisdiction to declare a CBDT circular ultra vires and therefore, the case does not fall in the exception clause and the contents of the decision read as under: “The revenue is in appeal under Section 260A of the Income Tax Act, 1961 (for short, 'the Act') against the order dated 29.10.2018 passed by the Income Tax Appellate Tribunal, Chandigarh (for short, 'the Tribunal'). Following substantial questions of law have been claimed: "1. Whether on the facts and in the circumstances of the case the Ld. Income Tax Appellate Tribunal is right in law in holding that even if a Company advances loans to its Member(s)/Share-holder(s)/Director(s) holding more than 10% of shares therein, and where admittedly such lending is 1 of 7 ITA No. 283 of 2019 [2] not in the usual course of its business, even then, the amounts so advanced, would not be covered under the definition of "dividends" as stated in section 2(22)(e) of the Income Tax Act, 1961 which is clearly contrary to the unambiguous language of the provision? ii) Whether on the facts and in the circumstances of the case, the Ld. Income Tax Appellate Tribunal is right in law in rejecting the finding of the Commissioner of Income Tax (Appeals)-2, Chandigarh that even though the amounts so received by the Assessee from the company, a major/considerable part thereof being 9 utilized for meeting Miscellaneous Expenses of the Assessee, still such transaction would take the colour of and/or relate to the usual course of business of the company which had transferred the amount? (iii) Whether on the facts and in the circumstances of the case, the Ld. Income Tax Appellate Tribunal is right in law in upsetting the well-reasoned and cogent findings as contained in the order passed by the Commissioner of Income Tax (Appeals)-2, Chandigarh even though no reasons in respect thereof have been rendered by it? (iv) Whether on the facts and in the circumstances of the case and in law, the order of Hon'ble ITAT is perverse stating that there is no exempt income during the year whereas in the return of income, the assessee has claimed total exempt income of Rs. 24,45,132/-, hence the ratio of case of M/s Lakhani Marketing INC is not applicable to the case of the assessee? (v) Whether on the facts and in the circumstances of the case and in law, the Hon'ble ITAT has erred in not upholding disallowance of Rs. 11,82,978/- u/s 14A of the Income Tax Act on the ground that disallowance made cannot exceed exempt income without appreciating the fact that there is no such restriction stipulated either in Section 14A of the Income Tax Act or Rule 8D of the Income Tax Rule? (vi) Whether on the facts and in the circumstances of the case and in law, the Hon'ble ITAT has erred in not upholding disallowance of Rs. 11,82,978/- u/s 14A of the Income Tax Act on the ground that disallowance made cannot exceed exempt income without appreciating the fact that applicability of Section 14A or Rule 8D does not depend on earning of income as held by Supreme Court in the case of CIT vs. Rajender Prasad Moody (1978), 115 ITR 519? (vii) Whether on the facts and in the circumstances of the case and in law, the Hon'ble ITAT has erred in not upholding disallowance of Rs. 11,82,978/- u/s 14A of the Income Tax Act on the ground that disallowance made cannot exceed exempt income without appreciating the fact that there is no such restriction in Section 14A or in rule 8D and further clarified by CBDT Circular No. 5 of 2014? (viii) Whether on the facts and in the circumstances of the case and in law, the Hon'ble ITAT has erred in ignoring the 3 of 7 ITA No. 283 of 2019 [4] legislative intent expressed in CBDT's Circular No. 5/2014 dated 11.2.2014, which explicitly states that expenses relatable to earning of exempt income have to be considered for disallowance irrespective of the fact whether any such income has been earned during the F.Y. or not as confirmed by Apex Court in Maxopp Investment Ltd. v. CIT, 91 Taxman.com 154 (SC)? (ix) Whether on the facts and in the circumstances of the case and in law, the Hon'ble ITAT has erred in holding that disallowance u/s 14A cannot be made where there is no exempt income, when Supreme Court has upheld the principles of apportionment and department is in SLP on the same issue in the cases of Moderate Leasing and Capital Services Pvt. Ltd. In ITA No. 102 of 2018, A. Y. 2009- 10 and Matrix Cellullar Service (P) Ltd. In ITA No. 484 of 2017 and Nilgiri Infrastructure Development Ltd. In ITA No. 135 of 2016 and Instant Holding Ltd. in ITA No. 2168 of 2011 and SLP has also been approved against the decision of 10 Hon'ble Jurisdictional High Court in the case of M/s Vardhman Chemtech Private Ltd. in ITA No. 322/2016? (x) Whether on the facts and in the circumstances of the case and in law, the Hon'ble ITAT has erred in law and fact in following the decision of Hon'ble High Courts whose facts were distinguishable from the assessee, ignoring the principal of apportionment regardless of exempt income laid down by Hon'ble Supreme Court decision in CIT v. Walfori Share and 4 of 7 ITA No. 283 of 2019 [5] Stock Brokers P Ltd., 326 ITR 1 (SC) and upheld by the Hon'ble Supreme Court in 91 Taxman.com 154 (SC)? (xi) Whether on the facts and in the circumstances of the case and in law, the Hon'ble ITAT has erred in deleting the addition of Rs. 11,82,978/- u/s 14A determined by the AO under rule 8D r.w.s. 14A to apportion interest expenditure incurred to invest in shares and equity instrument in view of the fact that no separate accounts are maintained by the assessee in relation to investments whose income is exempt from tax, and has large borrowed funds ignoring Apex Court decision in 91 Taxman.com 154 (SC)? (xii) Whether on the facts and in the circumstances of the case and in law, the Hon'ble ITAT has erred in law and fact in following the decision of Hon'ble High Court in Lakhani Marketing decided following decisions in the case of Hero Cycles Ltd., 323 ITR 204 and CIT v. Winsome Textile Industries Ltd., 319 ITR 204 whose facts are distinguishable from the assessee, ignoring the principal of apportionment laid down by Hon'ble Supreme Court decision in CIT v. Walfori Share and Stock Brothers P. Ltd., 326 ITR 1(SC), which has been confirmed in 91 Taxman.com 154 (SC) and thus legislation relying on Winsome Textiles Industries Ltd. stands superceded?" The brief facts are that the assessment year involved is 2013- 14. The income tax return was filed claiming deduction under Chapter VI-A of the Act. The case was selected for scrutiny. The Assessing Officer treated the loan received from M/s Acme Builders Private Limited as deemed dividends and made additions under the head "income from other sources". Further disallowance under Section 14A of the Act was also made vide order dated 29.1.2016. The first appeal filed was dismissed on 14.12.2016. The Tribunal allowed the appeal vide order dated 29.10.2018, hence the present appeal of the revenue. In the appeal, it is pleaded that the tax effect is `46,91,541/-, however it is argued that the case falls under the exception carved out in para 10(b) of CBDT Circular No.3 of 2018 dated 11.7.2018. The same is reproduced below: "10. Adverse judgments relating to the following issues should be contested on merits notwithstanding that the tax effect entailed is less than the monetary limits specified in para 3 above or there is no tax effect: xx xx xx (b) Where Board's order, Notification, Instruction or Circular has been held to be illegal or ultra vires, or xx xx xx From the perusal of the order of the Tribunal, it is not forth coming that any notification, order, instruction or circular was dealt with/ 11 relied upon by the Tribunal what to talk about the same being held illegal or ultra vires. Even otherwise, the Tribunal has no jurisdiction to declare a circular ultra vires. In our considered view, the case does not fall in the exception clause. The appeal is dismissed. However, the substantial question of law left open.” 9.3. In light of aforesaid discussions, we are of the considered view that the present case doesn’t fall under exception 10(b) of the CBDT Circular and the appeal so filed by the Revenue is hereby dismissed on account of low tax effect. The contentions on merits of the case have thus become infructious and are not dealt with and thus left open. 10. In the result, the appeal of the Revenue is dismissed. Order pronounced in the open Court on 28/03/2023. Sd/- Sd/- दवा संह $व%म संह यादव (DIVA SINGH) ( VIKRAM SINGH YADAV) या"यक सद#य / JUDICIAL MEMBER लेखा सद#य/ ACCOUNTANT MEMBER AG Date: 28/03/2023 ( + ! , - . - Copy of the order forwarded to : 1. The Appellant 2. The Respondent 3. $ / CIT 4. $ / 0 1 The CIT(A) 5. - 2 ग 4 5 & 4 5 678 ग9 DR, ITAT, CHANDIGARH 6. ग 8 : % Guard File ( + $ By order, ; # Assistant Registrar
Other Referred Cases
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