TMI Blog2012 (1) TMI 196X X X X Extracts X X X X X X X X Extracts X X X X ..... ssuing direction in respect of points which were neither subject matter of show cause notice u/s 263 nor for which any explanation was sought from assessee before issuing such direction to AO 5. That on the facts and in the circumstances of the case, the order passed by ld. CIT -2, Jodhpur is nothing but an act to frame the assessment order like AO which he could not have passed directly under the law and therefore, crossed scope of revision u/s 263. 2.2 The assessee is engaged in the business of contract work of roads. Before we consider the show cause notice issued u/s 263 of the Act., It will be useful to ascertain as to what transpired in assessment proceeding. (A) The AO has prepared a chart showing GP rate and NP rate of five assessment years including the assessment years under consideration (B) Assessee has maintained cash book and ledger and no stock register is maintained. (C) Assessee failed to give head wise break up of expense. Auditor has mentioned that there might be same personal expenses pertaining to partners (D) Assessee has not maintained log book, wages register, attendance register. (E) No complete expenses vouchers available in res ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d without verification. The AO should have seen TDS certificate of subsequent year to see as to whether any work in progress was there at the end of year. (6) There are creditors in the balance sheet and the AO has not called for any confirmation. There may be outstanding wages. 2.4 The assessee filed reply vide letters dated 7.9.2009 and 21.9.2009. No books of account or vouchers were produced before the ld CIT. The point wise reply is summarized as under. (1) The ld CIT (A) has upheld the rejection of books of accounts and hence no disallowance u/s 40A(3) can be made. The ld CIT held that issue at point no. 1 is not pressed (2) Issue stated at point No.2 was not pressed by ld CIT as the order of AO has merged with order of CIT (A) (3) Before the ld CIT, the assessee filed extracts of cash book to show that amounts were deposited out of cash in hand. The ld CIT held that the AO should have considered as the assessee build up substantial cash in hand. On this issue the ld CIT was of the opinion that the order is erroneous. (4) In respect of point No.4, it was contended by assessee that order of AO has merged with order of ld CIT (A) and hence no addition can be ma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... addition on account of suppression of closing stock can always be made even after rejection of books of accounts and application of a particular GP/NP rate. Reverting back of the discussion, it is found that it normally takes 30 to 45 days for receipt of cheque after intimation of completion of work to the contractee. When a particular work is completed, the contractor gives a detailed bill to the PWD/ contractee for payment. On receipt of such bill, the PWD authority/ contractee goes to the site and measures the actual work done including that of quality. A report is thereafter sent and the bill is screened. The bill passes through several authorities before a cheque is finally issued. All these procedures take at least a month. Under such circumstances, in contractors cases, the expenditures incurred in the last month normally becomes the closing work in progress. However, in the instant case, the AO failed to do any such exercise to determine the correct quantum of closing work in progress or closing stock of raw materials. The AO further failed to verify the return of the AY 2007- 08 to find out the TDS certificates issued in the month of April, 2006. The TDS certificates iss ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... material, labour, salary, transportation, diesel, telephone, motor parts, loading, unloading, mess, tyre tube, entertainment. Though the AO vide query no. 6 specifically directed the assessee to furnish the details of all expenses but the same was never complied with nor filed by the assessee nor the AO ever reminded the assessee that the requirement has not been complied with. In spite of that, the AO proceeded to complete the assessment. This shows the carelessness and negligent attitude of the AO. The question of making any inquiry or investigation did not arise for the reason that the preliminary details of various expenses remained to be furnished by the assessee. I believe that had the details been furnished by the assessee, the AO would have made at least some inquiries. During the course of such investigations/inquiries, the AO could have come across instances of bogus expenditures as also instances where expenditures were incurred out of books. Under such circumstance, the AO would have admittedly applied a higher NP rate as also made addition u/s 69A or 69B or 69C, as the case may be. The assessee was also duty bound to supply the relevant details of expenses as asked fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essment order so passed by the AO is erroneous as also prejudicial to the interest of revenue and therefore, the same is set-aside to the extent as above. The AO shall thoroughly verify and investigate the issue of closing stock of raw material and work in progress and take action as per law. He shall also investigate the purchases with reference to genuineness and purchases made outside the books of accounts and pass a well reasoned fresh assessment order. He shall also investigate as to whether expenditures have been claimed under all heads which are normally required and incurred in the case of road construction or other contract works as entered into by the assessee. It is found that in few cases, some of the expenditures so incurred are not entered in the books on account of non-availability of bill or shortage of cash on hand etc. etc. whereas other expenditures are inflated so as to give a balancing approach. Needless to mention that the AO shall provide an opportunity of being heard to the assessee in the matter. 8. In respect of issue stated at para P-5 of this office show cause notice u/s 263 dated 06.03.2009, it is submitted by the assessee before me that the AO rejec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the next year. Likewise, it is also observed from the TDS certificates placed on records that M/s Cairns Energy India Pvt. Ltd., PWD Barmer and PWD Jalore paid a sum of ₹ 7,41,896/-, ₹ 2,10,559/- and ₹ 21,36,082/- on 29.03.06 and 31.03.06, respectively. As mentioned above, no verifications were made with reference to closing stock of materials/closing work in progress. In any event, these facts suggest that the contracts continued and therefore, the assessee had certain quantum of closing stock of materials/closing work in progress. The AO also failed to verify the purchases made and wages incurred in the month of March, 2006 to ascertain the closing stock of materials as also work in progress. All the above facts goes to prove that the assessment was made in undue hurry and without making any enquires. The point to be noted here is that there is apparent and substantial suppression of closing stock and had the AO substituted the correct figure of closing stock/work in progress, he would have ended up with a much more addition than the addition made by him after rejecting the books of accounts and applying a particular NP rate. I have already discussed earlier ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s or outstanding wages or they represent loan entries. I disagree with the contention of the assessee that if the books of accounts are rejected, no addition on account of cash credit can be made. For instance, if an assessee files a return of income showing income below taxable limit or for that matter above the taxable limit and it also introduces crores of nongenuine loans/credits in its books of accounts and at the time of assessment, books etc. are not produced resulting into application of provisions of Section 145 and making some addition to the trading results by looking into past records or comparable cases. Whether under such circumstances, no addition could be made on account of such huge cash credits introduced in the books with ulterior motive? If the contention of the assessee is accepted, every assessee would indulge in this practice and it would be a very easy way of introducing the concealed income in the guise of cash credits. Besides that, addition on the basis of GP/NP rate after rejecting the books represents income from business whereas addition on account of cash credits represents deemed income and therefore, the two are entirely different without any ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d down by the Hon ble Rajasthan High Court in its decision dated 03.07.2008 in the case of M/s. Jhanwar Lal Vs. ITO, Bikaner Ors. In the said decision, it has been held that interest paid to third parties is not allowable when profit rate is estimated. Admittedly, under such circumstances, the assessment requires to be treated as erroneous as also prejudicial to the interest of revenue. 12. It is found that the AO after rejecting the books u/s 145(3) applied GP rate of 12.5% on contract receipts of ₹ 14,01,79,045/-. It implies that the AO rejected the books in respect of all items of expenditure relating to trading account but accepted as correct all items of expenditure debited to P L account. It is not understood as to how the AO adopted the above standards. It is incorrect as also unjustified to treat some of the expenditures debited in the books as correct and some as incorrect/unreliable. The books of accounts cannot be rejected in part. Once books are rejected, it means that the entire books are not reliable in so far as business income is concerned. Therefore, the AO admittedly erred as discussed above and the assessment is to be treated as erroneous as also preju ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erroneous as also prejudicial to the interest of revenue to the extent as stated above in the preceding paragraphs. The assessment order is accordingly set aside with the direction to the AO to examine the issues as mentioned above afresh, make in-depth investigations and pass a well reasoned fresh order depending upon the facts, inquiries, investigations and legal aspects of the case. 2.6 Before us the ld A/R has filed written submissions and these are reproduced as under:- 4. That the ld AO completed the assessment after due enquiry and passed the assessment order on 28-03-2008 and assessed the total income of ₹ 80,18,813 by making further addition of ₹ 997983/- under following heads:- a] Rejected the books of accounts and invoked the provisions of section 145(3) of the Act and computed the income by applying gross profit rate of 12.5% on the contract receipts and made an addition of ₹ 4,06,540/ b] Interest received on FDRs KVP treated as income from other sources amounting to ₹ 3,00,681/- c] Disallowances of interest amounting to ₹ 1,40,762/- as the has not charged interest from debtors. d] Lump sum addition of ₹ 1,50,0 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... te enhanced the income by disallowing the claim allowed by AO. 12. That assessee preferred appeals before Hon ble ITAT against the order u/s 263 as well as against the order enhancing the income by disallowing the claim of depreciation, interest paid to third parties and interest salary paid to partners as per terms of partnership deed. 13. That Hon ble Tribunal in the appeal against the order u/s 263 cancelled the order of ld CIT u/s 263 holding that the AO has rightly allowed the claim of depreciation, interest paid to third parties and interest and salary paid to partners as per terms of partnership deed. 14. That against the order of Hon ble ITAT the department filed reference before the Hon ble Rajasthan High Court which was rejected. The decision of Hon ble Rajasthan High Court is reported in 257 ITR 753 (Raj). 15. That the assessee s appeal against the order of AAC enhancing the income by disallowing the claim of depreciation, interest paid to third parties and interest and salary paid to partners was also allowed by the Hon ble Tribunal by reversing the order of ld CIT. 16. That department also filed reference application against the order of Hon ble Tribun ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sed the facts of the case I would like to submit on each ground of appeal raised in memo of appeal. GROUNDS OF APPEAL 1] Regarding grounds of appeal No. 1 2: - (a) That the reasons recorded by the ld CIT while setting aside the assessment order u/s 263 can broadly be divided under the following heads (i) Relating to violation of provisions of 40A(3) [P 1] (ii) Relating to non-examination of element of personal use of expenditure under the head traveling, rasoda and entertainment. [P 2] (iii) Relating to non-examination of applicability of sec 269SS on account of deposit in cash in the bank a/c [P 3] (iv) Relating to non-filing of details of expenditure incurred by the assessee and non furnishing of copy of a/c of transaction with parties above ₹ 5 Lac. [P 4] (v) Relating to non examination of issue of closing stock [P 5] (vi) Relating to failure of AO to obtain confirmation of a/c from the parties in whose names amounts are shown as out standing and application of provisions of sec 40(a)(1a). (b) That reasons recorded in the show cause notice at S. No. 1, 2, 4, 5 and 6 are related to the computation of income from contract business. In th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessment proceedings with reference to books of accounts. Further in respect of such out standing expenditure provisions of sec 68 are not applicable in light of decision of Hon ble Rajasthan High in the case of CIT v/s G.K. Contractors reported in 19 DTR Page 305. [A copy of which is enclosed herewith] b] That amounts deposited in bank a/c are not out of any cash borrowings so as to attract provision of sec 269SS but are out of cash in hand in the books of accounts and all the entries are recorded in the books of accounts. The AO had examined the books of accounts and verified the same on test check. Further if the credits in bank accounts are on a/c of cash loan received then the loan amount must have appeared in the balance sheet and in absence of any cash credits the presumption drawn is patently erroneous. However I am herewith filing relevant copies of cash book and the details of cash deposited in bank accounts which are out of cash in hand and was mostly on account of withdrawals from one a/c and deposit in other account. c] The perusal of the order passed u/s 263 shows that the order has been set aside merely on the ground of allegation of lack of enquiry. There is n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot revenue expenditure but an expenditure of capital nature. He simply asked the ITO to reexamine the matter. That, in our opinion, is not permissible. Further, inquiry and/or fresh determination can be directed by the Commissioner only after coming to a conclusion that the earlier finding of the ITO was erroneous and prejudicial to the interest of the Revenue. (iii) CIT V/s Jai Marwar Wine Contractors Reported in 251 ITR 785 (RAJASTHAN) 8. The very fact that CIT is required to make an order after affording an opportunity of hearing to the assessee ingrains in the process the requirement of recording reasons for its conclusion, as is necessary for any quasi judicial order required to be made by a quasi judicial authority. It cannot be doubted nor it has been questioned that orders under s. 263 bears stamps of quasi judicial nature and require to be supported by reasons for its conclusion. Necessary consequence is that while passing the order revising an order passed by subordinate officer of the rank of ITO or Asstt. CIT, the CIT must record reasons in support of his conclusion that the order is revised being erroneous and that it would be prejudicial to interests of Revenue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ied Engineers v/s CIT, 180 Taxman Page 70 (xiii) On the similar facts the ld CIT-2, Jodhpur set aside the assessment u/s 263 which was quashed by Hon'ble ITAT, Jodhpur Bench in the case of Amritlal Khatri v/s DCIT, Barmer ITA No. 233/Ju/2009 dated 19-07-2010. The Hon'ble Tribunal held as under [Para 11 P.B. 69-70]: - 11. For effective adjudication of this appeal the provision continued in section 263 is most relevant. As can be seen from the said provision it is found that the power of suomotto revision under sub-section 1 of section 263 of IT Act is in the nature of supervisory jurisdiction which can be exercised only if the order of the Assessing Officer is found erroneous and is also resulting in prejudice to the interest of revenue. These two circumstances must necessarily exist to empower the Commissioner to exercise the power of revision under this section. Any order of the Assessing Officer cannot be termed as erroneous unless it is not in accordance with law. It necessarily implies that if the order passed by the Assessing Officer is in accordance with law applicable thereto, the same cannot be branded as erroneous. On perusal of the records the CIT may be of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on of applicability of sec 269SS on account of deposit in cash in the bank a/c. (b) Relating to non-filing of details of expenditure incurred by the assessee and non-furnishing of copy of a/c of transaction with parties above ₹ 5 Lac. (c) Relating to non examination of issue of closing stock. (d) Relating to failure of AO to obtain confirmation of a/c from the parties in whose names amounts are shown as out standing and application of provisions of sec 40(a)(1a). (e) Relating to non examination of interest income from NSE of ₹ 4,50,000/- shown in balance sheet. (f) Relating to deduction of interest paid to third party which is contrary to the decision of Hon ble Rajasthan High Court in the case of Jhanwar lal v/s ITO, Bikaner, 321 ITR 400. [Not a issue in show cause notice] (g) Relating to failure of AO to obtain confirmation of a/c from the creditors which are shown as out standing and application of provisions of sec 40(a)(1a). a] As regards issues which are related to expenditure which are part of contract account and for which AO rejected the books of accounts and applied provisions of section 145(3) which stood confirmed by CIT(A) and as such o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ribute labour payment through such persons who sign the voucher showing total payment made through him on work site to the individual labour. The payment is shown in the books by writing the name of such person who sign the payment voucher showing total payment made by him to the individual labour. These persons are doing work at site on behalf of and as per direction of the appellant firm. (3) That on the given facts which is supported from books of accounts and vouchers the ld CIT erred in directing the AO to examine the application of section 40A (10) which has no application and the issue was examined by AO when he passed the assessment order u/s 143(3) and as such the assessment order passed under section 143(3) cannot be branded as erroneous or prejudicial to the interest of Revenue. (ii) The ld CIT in his order has not disputed the rejection of books of accounts made by AO and application of profit rate. The application of provisio to section 145 was held by CIT (A). Once the AO has rejected the books of accounts by invoking provisions of section 145(3) estimated income by application of profit rate than the same books cannot be considered for making specific disallo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eard both the sides and perused the relevant material on record. In the first ground of Revenue s appeal, the only question was that of the trading addition by applying a particular gross profit rate to the declared turnover. The amount of Gross Profit encompasses the effect of all individual items debited or credited to the trading account. When it is held that a particular rate of Gross Profit is applicable, that would take care of the figures of opening stock, purchases, direct expenses, sales and closing stock, etc., which find place in their trading account. Having held that the particular Gross Profit rate is appropriate, it is not open to the Revenue authorities to go back to the individual figures of trading account again and make separate additions. In our considered opinion, when the trading addition has been made by applying particular Gross Profit rate, there is no question of considering the valuation of closing stock on a lower of higher level once again. Accordingly, no addition for under valuation of closing stock can be sustained. We order for the deletion of the entire addition of ₹ 26,20,509/-. The ground of appeal of the assessee is accordingly accepted an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e balance sheet and in absence of any cash credits the presumption drawn is patently erroneous. The relevant copies of cash book and the detail of cash deposited in bank accounts which proves the deposits in the bank is out of cash in hand and was mostly on account of withdrawals from one a/c and deposit in other account. (iii) It is humbly submitted that the ld AO passed the assessment order in light of the direction of the ld CIT contained in the order u/s 263/143(3) and was satisfied in respect of all the issues and made no adverse comments on the above issues and as such the above reasons cannot be made a ground for considering the order passed by AO as erroneous or prejudicial to the interest of Revenue. c] Grounds taken in the order u/s 263 but was not part of show cause notice u/s 263 S.No. Grounds taken in order but not part of show cause notice u/s 263 Submission Evidences 1 The ld CIT in show cause notice nowhere objected the interest paid to third parties as deductible from the profit arrived after application of net profit rate. This issue could not have been raised in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 8377; 3,00,681/- on account of interest received from bank, NSC FDR as per finding recorded in Para 3 at page No. 4 5 which reads as under: - From the details of interest it is revealed that the assessee has claimed interest payment of ₹ 35,83,211/- @ 15% to 18%. Out of the above ₹ 12,33,232/- have been paid to Banks and Finance companies and the remaining amount of ₹ 23,49,980/- have been paid to the HUF of the partners and the other family members (persons specified u/s 40A(2)b) and the relatives. This payment of interest is besides the interest payment allowable to the partners. Further the assessee has claimed to receive interest of ₹ 3,00,681/-, which includes the interest on refund of ₹ 49,440/- received in this year. If the interest of refund is excluded, the receipt of interest remains at ₹ 2,51,241/- only and the same is from the interest of FDRs with the Banks. It is to be seen that the interest income received from Bank/NSC/FDR/IT Department does not represent contract business income and, therefore, requires to be separately taxed. This view gets support from the decision reported in the cases of M.K. Gupta v/s ITO (XXXI Ta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... case of assessee by Hon ble Rajasthan High Court reported in 257 ITR 753 and the same was allowed right from assessment year 1993-94 to 2007-08 by AO and was not objected in all the years in which appeals were filed. (iv) That in the show cause notice the ld CIT has no where objected to the deductibility of interest paid to third parties and interest on NSC shown in balance sheet. When a issues which were not subject matter of notice u/s 263 cannot form a basis while passing the order u/s 263 as held by Hon'ble Delhi High Court in the case of CIT v/s Contimeters Electricals P. Ltd. reported in 317 ITR 249 following the decision of Hon'ble Supreme Court in the case of Commissioner of Customs vs. Toyo Engg. India Ltd. (2006) 7 SCC 592. (v) Regarding Interest paid to third party (1) That when the Hon'ble Rajasthan High Court in the case of the appellant himself reported in [257 ITR 753] and in the case of Bhawan Va Path Nirman (Bohra) Company [258 ITR 431] held that interest paid to third parties is allowable than the direction issued by the ld CIT in the order u/s 263 is itself erroneous and this issue cannot be made a foundation for setting aside the comp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... simply rejected the books of accounts and applied the net profit rate. The AO is an investigator as well as arbitrator. If the AO has not made necessary enquiry then the order of the AO is erroneous and prejudicial to the interest of the revenue. 2.10 The ld. DR drew our attention to the assessment order passed by the AO. As a result of order u/s 263 of the Act, the assessment has been made at an income of ₹ 1.87 crores as against return of income of ₹ 67,83,280/-. It was therefore, submitted that earlier assessment order was erroneous and prejudicial to the interest of the revenue. The ld. DR relied upon the following decisions. 1. CIT Vs. Sunil Goyal, 176 Taxman 184 (Uttra) - The AO accepted huge sundry credits without any verification. The Hon'ble Uttrakhan High Court held that the order is erroneous in case the AO has accepted huge sundry credits without any verification. 2. CIT Vs. Assam Tea House, 48 DTR 122 (P H) the Hon'ble Punjab Haryana High Court held that order is erroneous in case there is lack of proper enquiry. The ld. CIT noticed that the assessee has not produced any record while the AO has mentioned that records of statements were ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... proceeding before ld. CIT filed the extract of cash book and this shows that the cash was deposited out of the cash in hand. The assessee has filed the tax audit report. The auditor is required to give particulars of different loans or deposits in the Audit Report. These details are available as Annexure of tax audit report. In this tax audit report , it is clearly mentioned that assessee has not deposited the loan except otherwise than cheque or draft. The ld. CIT has not recorded any finding in his order that the assessee has accepted the deposits in cash in violation of provision of Section 269SS. It has not been held that details mentioned in tax audit report are factually incorrect or wrong. Thus there was no case of holding the order as erroneous and prejudicial to the interest of the revenue on the issue that the AO has not looked into the contravention of provision of Section 269SS. 2.14 The 4th issue on which the ld. CIT has held that order is erroneous and prejudicial to the interest of the revenue. 2.15 The AO in his order has clearly mentioned that the assessee has not maintained the stock register. The AO has already made an enquiry in respect of the maintenance ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mined the sundry creditors in the balance sheet. The Hon'ble Jurisdictional High Court in the case of CIT Vs. G.K. Contractors, 19 DTR 305 has held that if the books of accounts are rejected then no separate adition can be made on account of cash credit u/s 68 of the Act even though the assessee has failed to discharge its onus of proof in explaining the amount shown in the books of accounts as market outstanding. In view of the decision of Hon'ble Jurisdictional High Court, it cannot be said that the order of the AO is erroneous and prejudicial to the interest of the revenue. The ITAT Jodhpur Bench in the case of Amritlal Khatri Vs. DCIT, Barmer (ITA No. 233/ JU/2009 dated 19-07-2010) on similar issue held that the ld. CIT was not justified in holding the order of the AO as erroneous and prejudicial to the interest of the revenue. It will be useful to reproduce para 11 from that decision. 11. For effective adjudication of this appeal the provision contained in Section 263 is most relevant. As can be seen from the said provision, it is found that the power of suo-motto revision sub-section 1 of Section 263 of I.T. Act is in the nature of supervisory jurisdiction which ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... order passed by the CIT is sustainable for legal scrutiny and accordingly the same is hereby set aside by allowing the issues raised by the assessee in this appeal. 2.18 The ITAT Jodhpur Bench in the case of Shri Ashok Kumar Dhariwal, Barmer Vs. ACIT, (ITA No. 153/JU/2010 dated 29-07-201) held that provision of Section 40a(ia) cannot be invoked when the books of accounts are rejected after considering the decision of ITAT Hyderabad Bench in the case of Teja Construction Vs. ACIT in ITA No. 308/Hyd//2009 reported in (2010) 36 DTR (Hyd) (Trib) 220 . If there is one possible view which the AO has taken then the order cannot be considered as erroneous and prejudicial to the interest of the revenue. The decision of Hyderabd Bench is reported at 129 TTJ (UO) 57, Teja Construction co. Vs. ACIT. The ITAT Jaipur Bench in the case of Singhal Builders Contractors Vs. Addl. CIT 133 TTJ (UO) 102 held that no disallowance u/s 40a(ia) cannot be made in case books of accounts have been rejected. We have also gone through the case laws on which the ld. DR has relied upon. We agree with the views of the ld. DR that order is erroneous if the AO has not made any enquiry. We had already discussed ..... 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