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Depreciation: cost to secure non competition or reduce competition can be a part of depreciable intangible asset. |
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Depreciation: cost to secure non competition or reduce competition can be a part of depreciable intangible asset. |
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There are different views possible to claim costs incurred to reduce competition. Facts and circumstances will paly a role furthermore, depending on amount of costs involved and period of benefits and actual benefits derived will also be relevant factor for businessman to decide possible ways to claim deduction so as to secure best possible tax advantage. Claims have been made and allowed for depreciation as well as revenue expenses for such costs which are commonly described as non competion fees or compensation. The person who is in a position to compete and agree not to indulge into competition really forgoe his possible income. The person who pay secure to a situation for reduced competition. Reduced competition enables the person paying to rest assured for reduced competition and therefore, he can carry busienss more conveniently and profitably. Reduced competition enables him to:
Restrictions and compensatation: Restrictions placed on receiving parties should be reasonable and bonafide and explanable. It should not go against public policy or under any prohibitive manner. Compensatation paid should also be bonafide and reasonable. The reasonableness will have to be decided by businessman and negotiation skils and capabilities of concerned parties. Therefore, decision of busienssman/ assessee should prevail. However, any misuse of such means which can be considered as tax avoidance or against public policy can face reasons for disallowance. Method of accounting: The nature of goodwill, various type of intangible assets , their usefull life can vary very widely etc. are such that a fixed formula for their allowability is not suitable. Therefore, tailor made formula for depreciation or amortization should be permitted so that charge to revenue can be computed in a scientific manner depending on actual facts and cirumstances of any case. In this article aspect of depreciation is considered with some of important judgments summarised and analyzed. 2019 (6) TMI 891 - BOMBAY HIGH COURT (Department’s SLP is pending.) PR. COMMISISONER OF INCOME TAX – 7 VERSUS PIRAMAL GLASS LIMITEDDepreciation on payment of non-compete fees Similar issue has been considered by the different High Courts and held in favour of the Assessee. A reference can be made to the decision of the Division Bench of the Gujarat High Court in the case of Pr. CIT v. Ferromatice Milacron India (P.) Limited [2018 (10) TMI 615 - GUJARAT HIGH COURT]. (note 1_) It was also the case where the Assessee had incurred expenditure pursuant to the non-compete agreement and claimed depreciation on such asset. Rights acquired by the assessee under the said agreement not only give enduring benefit, protected the assessee's business against competence, that too from a person who had closely worked with the assessee in the same business. The expression "or any other business or commercial rights of similar nature" used in Explanation 3 to sub-section 32(1)(ii) is wide enough to include the present situation. - decided in favour of assessee. {Note 1- However in this HC judgment there is no matter of non-compete fees . In corresponding ITAT order non compete fees has been considered depreciable intangible asset ad department has not challenged the same in asppeal filed against the same judgment of ITAT. So author wrote to editors of website for correction/ clarification of link as may be necessary.} In this case departmental SLP has been filed as per the following information gathered from the website of the Supreme Court:
2015 (7) TMI 620 - SC ORDER ( broader issues about intangible assets and goodwill) DEPUTY C.I.T. VERSUS AREVA T & D INDIA LTD. Depreciation on goodwill account - Held that:- HC examined this issue in the light of legal provisions of the Act and various judgments of the Hon'ble Apex Court and finally concluded that specified intangible assets acquired under slump sale agreement were in the nature of "business or commercial rights of similar nature" specified in section 32(1)(ii) of the Act and were accordingly eligible for depreciation. [(2012 (4) TMI 79 - DELHI HIGH COURT] Special Leave Petition is dismissed on the ground of delay as well as on merits. - Decided in favour of assessee. 2012 (4) TMI 79 - DELHI HIGH COURT Depreciation on intangible assets being “business and commercial rights” - assessee, vide slump sale agreement, acquired power transmission and distribution business as a going concern for a total sale consideration of ₹ 44.7 crores out of which ₹ 16.58 crores were paid for acquisition of “business and commercial rights” being business claims; business information; business records; contracts; skilled employees; know-how described as “goodwill” –dis-allowance of depreciation on the amount described as goodwill by Revenue – Held that:- Addition of the words “business or commercial rights of similar nature” after the specified intangible assets clearly demonstrates intention of Legislature to provide depreciation to other categories of intangible assets which are not exhaustively enumerated. It is observed that in case of the assessee, intangible assets being Business claims; business information; business records; contracts; skilled employees; knowhow were invaluable and resulted in carrying on the transmission and distribution business by the assessee, without any interruption. Therefore, specified intangible assets acquired under slump sale agreement were in the nature of “business or commercial rights of similar nature” specified in Section 32(1)(ii) and were accordingly eligible for depreciation. It is not necessary to decide the alternative submission made on behalf of the assessee that goodwill per se is eligible for depreciation u/s 32(1)(ii) – Decided in favor of assessee. No.- ITA No.315/2010, ITA No.1151/2010, ITA No.1152/2010 In this case although ‘non compete fees’ has nto found mention directly, however, considering inclusive and wider definition ‘ non - competition benefits’ is a part of intangible assets of business. 2013 (11) TMI 186 - ITAT CHENNAI AREVA T & D INDIA LIMITED VERSUS THE DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAXDisallowance of Depreciation on Goodwill – Payment Made Over and Above the NAV – Slump Sale Agreement – Business Transfer - appellant contended that as part of business transfer there were certain other intangible assets that were acquired viz., knowhow, employees, business information, business records - Held that:- The specified intangible assets acquired under slump sale agreement were in the nature of "business or commercial rights of similar nature" specified in Section 32(1)(ii) of the Act and were accordingly eligible for depreciation under that Section - Decided in favor of assessee. Areva T & D India Ltd. v. DCIT [2012 (4) TMI 79 - DELHI HIGH COURT] - applying the principle of ejusdem generis, which provided that where there were general words following particular and specific words, the meaning of the latter words shall be confined to things of the same kind, as specified for interpreting the expression "business or commercial rights of similar nature" specified in Section 32(1)(ii) of the Act, it is seen that such rights need not answer the description of "knowhow, patents, trademarks, licenses or franchises" but must be of similar nature as the specified assets – Decided in faovur of Assessee. JOHNSON MATTHEY CHEMICALS INDIA PRIVATE LIMITED, VERSUS DEPUTY COMMISSIONER OF INCOME TAX, PANVEL CIRCLE, PANVELDisallowance of depreciation on goodwill - As relying on assessee’s own case for A.Y. 2003-04 [2016 (2) TMI 187 - ITAT PUNE] it is clear that the allowance of depreciation on goodwill is granted. There was no contrary view placed by the ld. DR before us. It is clear that the allowance of depreciation on non-compete fees is allowable. Disallowance of depreciation on technical know-how and other assets - HELD THAT:- In the light of the orders of this Tribunal in assessee’s own case for A.Y. 2004-05 [2018 (1) TMI 12 - ITAT PUNE] it is clear that the allowance of depreciation on technical know-how and other assets is granted. There was no contrary view placed by the ld. DR before us. - Decided in favour of assessee. ASSTT. COMMISSIONER OF INCOME TAX, RAIGAD VERSUS JOHNSON MATTHEY CHEMICALS INDIA PVT. LTD. AND VICA-VERSADepreciation claimed on payment of non-compete fees - Held that:- Non-compete payment is capital in nature and falls in the category of an intangible asset. Thus, non-compete payment is eligible for depreciation u/s. 32(1)(ii) of the Act. Disallowance of depreciation claimed on goodwill u/s. 32(1)(ii) - Held that:- Following the decision rendered in the case of Commissioner of Income Tax Vs. Smifs Securities Ltd. (2012 (8) TMI 713 - SUPREME COURT ), the Hon'ble Bombay High Court in the case of Commissioner of Income Tax Vs. Birla Global Asset Finance Co. Ltd. (2012 (8) TMI 773 - BOMBAY HIGH COURT ) held that depreciation in respect of intangible assets constituting goodwill is allowable. 2021 (8) TMI 501 - ITAT AHMEDABAD DCIT, CIRCLE-2 (1) (2) AHMEDABAD VERSUS MILACRON INDIA PVT. LTD. (FORMERLY KNOWN AS FERROMATIK MILACRON INDIA PVT. LTD.)Disallowance of depreciation on non-compete fees - Assessee stated that the non-compete payment being in the nature of payment and commercial right as referred to in section 32(1)(ii) has been capitalized and depreciation has been claimed at the rate applicable to the block of "Intangible assets" - HELD THAT:- As decided in own case[2018 (4) TMI 1879 - ITAT AHMEDABAD]non-compete fee paid by the appellant to Mr. Patel is a capital expenditure and the appellant has acquired an intangible right which is depreciable and depreciation claimed is allowable under section 32(1)(ii) of the Act. The asset is depreciable as the contract is enforceable only for three years and it is not forever. The disallowance made by the AO is therefore, directed to be deleted. 2018 (4) TMI 1879 - ITAT AHMEDABAD FERROMATIC MILACRON INDIA PVT. LTD. VERSUS THE DCIT, CIRCLE-2 (1) (1) , AHMEDABADDisallowance of depreciation - as per AO claim of depreciation on non-compete fees is not justified because the payment of non-compete fees did not merely facilitate conduct of business as it would be a capital expenditure by merely because of capital expenditure it would not be necessary that it is eligible for depreciation - HELD THAT:- Non-compete fee paid by the assessee to Mr. Patel is a capital expenditure and the assessee has acquired an intangible right which is depreciable and depreciation claimed is allowable under section 32(1)(ii) of the Act. Therefore, we do not find any reason to interfere in the decision of the Ld. CIT(A). Accordingly, the appeal of the revenue is dismissed. Note In this case department filed appeal but no ground / Question of law was on issue of non compete fees. see Pr. CIT v. Ferromatice Milacron India (P.) Limited [2018 (10) TMI 615 - GUJARAT HIGH COURT]. 2022 (5) TMI 104 - ITAT MUMBAI Disallowance towards non compete fees treated as revenue in nature and charged to tax - HELD THAT:- We observe that assessee has entered into joint venture with Sharp Corporation, Japan for the purpose of setting up a joint venture company in India (which is an independent company). With the object of marketing, selling and servicing in India certain electronic office products and other equipments. Apart from entering into joint venture agreement, assessee also entered into a Cooperation Agreement in order to avoid competing with the business of joint venture company, which assessee and Sharp Corporation, Japan were interested to develop in India. It is a common interest for both the partners, so that the joint venture company, which has set up in India should not suffer the competition from any of the companies associated with the assessee or assessee itself. It is clear from the record that it is in the interest of the assessee not to venture into the operations of the new joint venture company. In order to avoid any loss, which assessee may suffer due to non compete, the joint venture partner agreed to compensate the same. It is nowhere connected with the day to day running of the assessee company as perceived by the tax authorities that it is a compensation for the loss incurred by the assessee. Therefore, we are not in agreement with the tax authorities that it is compensation for allowing the facilities or widespread network in marketing or selling the products of the joint venture. and it is only a non compete fees paid by the joint venture partner to restrict the assessee not to curtail the development of the new joint venture company. Therefore, we are inclined to allow the claim of the assessee - 2021 (10) TMI 615 - ITAT CHENNAI - relevant part of order analzed: M/S. CAVINKARE PRIVATE LIMITED VERSUS THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2 (1) , CHENNAI.Disallowance of depreciation on non-compete fees - Whether it has kind of right which could be owned or transfer to third person similar to rights of any other kind of similar nature as mentioned in section 32(1)(ii).? - HELD THAT:- We are of the considered view that non-compete fee paid by the assessee in terms of Memorandum of Understanding for acquiring trademark is nothing but an intangible asset in the nature of any other business or commercial rights of similar nature which qualifies for depreciation u/s. 32(1)(ii) of the Act. Hence, we direct the AO to delete the additions made towards disallowance of depreciation claimed on non-compete fee. ITA No.1597/Chny/2018 The first issue that came up for our consideration from ground nos. 3 & 4 of assessee appeal is disallowance of depreciation on non-compete fees. The fact with regard to the impugned dispute are that the assessee has entered into a Memorandum of Understanding on 26.11.2003 for acquiring the trademark ‘Ruchi’ from M/s. Ruchi Food Products, a partnership firm and as per said MoU, the assessee has acquired trademark ‘Ruchi’ along with associate copyrights, goodwill, formulations and know-how relating to process, ingredient, technical or otherwise for manufacture/production of the products agreed under said trademark for consideration of ₹ 15,20,00,000/-. The assessee had also entered into supplemental Memorandum of Understanding dated 15.04.2004 and bifurcated agreed consideration paid in terms of MoU dated 26.11.2003, into consideration paid for acquiring patents, copyrights, know-how/ formulation and non-compete fees and as per said agreement a sum of ₹ 3 crores has been assigned for non-compete trade agreement. In pursuance to above two MoUs’ the assessee entered into a non-compete agreement dated 26.05.2004 and as per said agreement, the seller of Ruchi trademark was prevented from doing any business for a period of 10 years for which a consideration of ₹ 3 crores has been paid. The assessee has treated consideration paid in terms of non-compete agreement as an intangible asset falls under ‘any other business or commercial rights of similar nature’ as envisaged u/s. 32(1)(ii) of Act and claimed depreciation @ 25%. The AO has disallowed depreciation claimed on non-compete fee u/s. 32(1)(ii) of the Act on the ground that non-compete fees paid does not confer upon the assessee any right which would be used for the business, but it only restrains other person from carrying on his business in competition with the assessee business. Therefore, he observed that non-compete agreement between the parties restraining the other party in engaging in a competing business, does not in anyway result in any right which could be treated as an asset. The intangible asset defined in the depreciation table contemplates only rights acquired and capable of being exercised by the owner. Therefore, consideration paid for non-compete agreement is neither asset whether it is tangible or intangible which could be used for the business of the assessee and hence disallowed depreciation claimed on non-compete fees and added back to the total income of the assessee. 5. The Ld. AR for the assessee submitted that the Ld. CIT(A) has erred in sustaining addition made by the AO towards disallowance of depreciation on non-compete fees without appreciating the fact that non-compete fee paid by the assessee in terms of MoU for acquiring trademark Ruchi is part of main agreement of acquiring trademark and other technical know-how, in the nature of any other business or commercial rights of similar nature eligible for depreciation u/s. 32(1)(ii) of the IT Act, 1961. The Ld. AR for the assessee further referring to the agreement between the parties submitted that after going through the clauses of MoU and non-compete agreement, the seller acknowledges that the food business intensely competitive and as such, the technical and business information including, but not limited to recipes, secret ingredients, preserving techniques was handed over to the assessee and further craved not to participate in, own, manage, operate or conduct any business or have any interest, either directly or indirectly in manufacturing or marketing or distributing or selling in any packaged food business either in India or anywhere in the world for the period of 10 years from the date of acquiring of assignment of the brand Ruchi which resulted in a kind of right in business similar to intangible asset defined u/s. 32(1)(ii) of the Act. He further referring to the decision of Hon’ble High Court of Madras in the case of Pentasoft Technologies Ltd vs DCIT, [2013] 96 DTR 223 submitted that Hon’ble Jurisdictional High Court has clearly held that noncompete fees paid is in the nature of any other business or commercial rights which is eligible for depreciation u/s. 32(1)(ii) of the Act. 6. The Ld. DR on the other hand strongly supporting the order of the CIT(A) submitted that non-compete fees is in the nature of negative right and it cannot be a commercial right of similar nature and the expression similar nature shall be relatable to patents, copy rights and trademark license or franchise or any other business asset. Therefore, she submitted that this negative right cannot be construed either as the license or as a commercial right to be eligible for deduction u/s. 32(1)(ii) of the Act, 1961. She further referring to decision of the Hon’ble Delhi High Court in the case of Sharp Business System vs CIT in ITA No. 492/12 dated 05.11.2012 submitted that intangibles spelt out in section 32(1)(ii) i.e., know-how, patents, copyright, trademark license/franchise as any other right of a similar kind it confers business or commercial or any other business or commercial right of a similar nature has to be intangible asset. The nature of this rights mentioned clearly spell out an element of exclusivity which ensures to the assessee as a sequel to the ownership. However, in the case of non-compete agreement, the advantage is a restricted one, in point of time and it does not necessarily confer any exclusive right to carry on the primary business activity. Therefore, said negative right cannot be construed as any other business or commercial right of similar nature which qualifies for depreciation u/s. 32(1)(ii) of the Act. 7. We have heard both the parties, perused the materials available on record and gone through orders of the authorities below. We have also carefully considered case laws cited by both parties. Admittedly, the assessee has paid non-compete fees in terms of an agreement which is carved out from main MoU between the parties for transfer of trademark called ‘Ruchi’. The assessee has entered into an agreement for acquiring trademark ‘Ruchi’ along with other bundle of rights and as per said MoU, the parties have entered into a non-compete agreement and restricted the seller of trademark not to have any kind of right in the business activity for a period of 10 years for which the assessee has paid consideration of ₹ 3 crores. The assessee has treated said consideration as intangible asset, being any other business or commercial right of similar nature and claimed depreciation u/s. 32(1)(ii) of the Act. The AO has disallowed depreciation claimed on non-compete fee on the ground that non-compete fee paid by the assessee neither gives rise to any kind of asset whether tangible or intangible which could be owned and transferable to third party. Therefore, he opined that noncompete fee paid by the assessee for restricting other party to restrain from doing similar kind of business activity for a particular period is nothing but a negative right which cannot be treated as intangible asset, know-how, patent, copy rights, trademark, license, franchise or any other business of the commercial right of similar nature. The AO has given his own reasons for denying depreciation claimed on non-compete fees and, according to him non-compete fee paid does not confer upon the assessee any right which would be used for the business. However, it only restrain the other person from carrying on his business in competition with the assessee’s business. Therefore, he opined that definition of intangible u/s. 32(1)(ii), i.e., any other business or commercial rights of similar nature speaks about a kind of right which could be owned and transferable to the third party, but not to a negative rights called non-compete fee paid for restraining the other party from doing business. 7.1 We have given our thoughtful consideration to the reasons given by the AO in light of arguments of the assessee and we ourselves do not subscribe to reasons given by the AO, for the simple reason that non-compete fee is generally paid to a person who is in an advantageous position, because the payee is in a position where he can, if he so desires, create a hostile environment for the payer’s business either starting a competing business in the same field or by helping the growth of the payer’s competitor to ensure that such person does not indulge in such competing behavior, and to ensuring that the payer can carry on business without bothering about the competition. Further, non-compete agreement are generally for specific periods and after an expiry of the period, the advantage in the non-compete agreement disappears since the payee is no longer bound by it. Hence, we are of the considered view that non-compete fee paid in pursuant to any agreement for transfer of patents, know-how, copy rights or trademark is in the nature of any other business or commercial rights of similar nature, being intangible asset, which is eligible for depreciation u/s. 32(1)(ii) of the Act. The fact that non-compete fee has not been specifically mentioned in section 32(1)(ii) would not result in a negative right inference that depreciation is not allowable on non-compete fee, because of the presence of the phrase “or any other business of commercial rights of similar nature which shows that the legislature intended clause (ii) of section 32(1) to be an inclusive clause and not an exhaustive once restricted to the assets specifically mentioned therein. Therefore, we are of the considered view that there is a merit in the argument of the assessee that non-compete fee paid for restraining the other party from doing competitive business for a specific period in pursuant to a trademark agreement is intangible in the nature of any other business or commercial rights of similar nature which qualifies with depreciation u/s. 32(1)(ii) of the Act. This legal position if fortified by the decision of the Hon’ble Madras High Court in the case of Pentasoft Technologies Ltd vs DCIT, supra, where the Hon’ble Madras High Court considered relevant fact by following the decision of Supreme Court in the case of Techno Shares and Stocks Ltd vs CIT 327 ITR 323 held that non-compete fee paid by an assessee is in the nature of any other business or commercial right which is eligible for depreciation u/s. 32(1)(ii) of the Act. The Hon’ble High Court while deciding the issue, has laid down the ratio and held that under non-compete agreement the transferor had transferred all its rights in respect of the trademark and such right strengthen those rights under the said non-composite agreement which includes a non-compete clause by virtue of which, the transferor restrains from using the same trademark, copyrights etc. Therefore, the Hon’ble High Court held that non-compete clause under the agreement should be a supporting clause to the transferor of the copy rights and patents rather to strengthen the commercial right, which was transferred in favour of the assessee. A similar view has been taken by a Hon’ble Bombay High Court in the PCIT vs Ferromatic Milacron India Pvt Ltd, 2018, 99 Taxmann.com 154, where it has considered identical issue and held that non-compete fee is in the nature of any other business or commercial right of similar nature used in explanation to section 32(1)(ii) of the Act and thus, eligible for depreciation. As regard the case laws cited by the Ld. DR in the case of Sharp Business System s CIT 492/2012, although, the Hon’ble Delhi High Court taken a different view and held that non-compete fees is a kind of negative right which does not give rise to any kind of right which could be owned or transfer to third person similar to rights of any other kind of similar nature as mentioned in section 32(1)(ii). Although divergent views are expressed by two different High Courts, but because the Hob’ble Jurisdictional High Court of Madras has taken a view in favour of the assessee in the case of Pentasoft Technologies Ltd vs DCIT, we prefer to follow the Jurisdictional High Court decision which is binding in nature. 7.2 In this view of the matter and considering the ratio of various case laws, we are of the considered view that noncompete fee paid by the assessee in terms of Memorandum of Understanding for acquiring trademark is nothing but an intangible asset in the nature of any other business or commercial rights of similar nature which qualifies for depreciation u/s. 32(1)(ii) of the Act. Hence, we direct the AO to delete the additions made towards disallowance of depreciation claimed on non-compete fee. 2021 (10) TMI 242 - BOMBAY HIGH COURT PR. COMMISSIONER OF INCOME TAX – 10 VERSUS M/S. INDIA MEDTRONIC PVT. LTD.Claim of depreciation - Payment of non-compete fee - Whether non-compete fees is an intangible asset of any other business or commercial rights of similar nature as per section 32 (1) (ii)? - HELD THAT:- The Division Bench of this Court in Piramal Glass Limited, [2019 (6) TMI 891 - BOMBAY HIGH COURT] has held that the payment of non-compete fee would fall under the expression “or any other business or commercial rights of similar nature” used in explanation 3 to Sub Section 32 (1) (ii). Also decided in Ferromatice Milacron India (P.) Limited [2018 (10) TMI 615 - GUJARAT HIGH COURT] rights acquired by the assessee under the said agreement not only give enduring benefit, protected the assessee's business against competence, that too from a person who had closely worked with the assessee in the same business. The expression "or any other business or commercial rights of similar nature" used in Explanation 3 to subsection 32(1)(ii) is wide enough to include the present situation - Decided in favour of assessee. 2021 (4) TMI 1201 - ITAT PUNE ( in this case matter was restored to AO for examination of calculations of amount) COVENTYA INDIA PRIVATE LIMITED VERSUS THE INCOME TAX OFFICER, WARD-1 (3) , PUNEDisallowance of depreciation on Intangible assets - HELD THAT:- As decided in own case [2020 (2) TMI 936 - ITAT PUNE]Tribunal allowed depreciation on Intangible assets of Non compete fees, Distribution net work rights and Customer list (depreciation on Goodwill was suo motu allowed by the AO). The authorities below have relied on their respective orders for the earlier years, which have been adjudicated by the Tribunal. In absence of any distinguishing facts having been brought to our notice by the ld. DR, respectfully following the precedent, we hold the assessee entitled to depreciation u/s.32(1)(ii) of the Act on the opening written down value of Non compete fees, Distribution of net work rights and Customer list. Depreciation of goodwill - The Hon’ble Supreme Court in Smifs Securities Ltd [2012 (8) TMI 713 - SUPREME COURT] has allowed depreciation on goodwill. Respectfully following the same, we direct to allow depreciation on Goodwill also. The impugned order is overturned pro tanto resulting into grant of depreciation on opening written down value of the intangible assets. Addition to the Intangible asset of Non compete fees and claimed depreciation thereon also - AR submitted that the assessee, while entering into original agreement with CRIL, agreed for certain more payment in future years on the basis of a formula. The said amount of ₹ 1.00 crore was stated to be pursuant to such formulae - HELD THAT:- No calculation in accordance with the formula has been placed on record. In these circumstances, we set aside the impugned order on this score and remit the matter to the file of the Assessing Officer for examining true nature of ₹ 1 crore. If the same is found out to be correct in accordance with the terms of the agreement as to the quantum and nature, then deprecation on such additional amount of ₹ 1 crore should also be granted. In the otherwise scenario, the AO is free to decide the issue as per law. Needless to say, the assessee will be granted reasonable opportunity of hearing.
By: DEV KUMAR KOTHARI - June 23, 2022
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