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Adani Wilmar Ltd. Versus DCIT, Circle-1, Ahmedabad

Revision u/s 263 - income from incentives undisclosed - Held that:- As far as the first issue is concerned, it is not the case of the Revenue that the assessee had income from incentives which were ultimately not offered. The assessee has explained to the AO that on account of procedural lapses, it could not claim the incentives, and therefore, no income has accrued to him. This stand of the assessee must have been examined by the AO. We could appreciate the stand of the ld.Commssioner, had she .....

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Commissioner. Ld. Commissioner has made an observation that there is an inadequate inquiry. As per the decision of the Hon'ble Gujarat High Court in the case of Amit Corporation (2012 (6) TMI 593 - GUJARAT HIGH COURT ) lack of inquiry would give jurisdiction to the Commissioner to take action under section 263. But the alleged inadequacy of inquiry would not empower the ld. Commissioner to take action under section 263 of the Act. In view of above discussion, we allow the appeal of the assessee .....

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assed under section 263 of the Income Tax Act, 1961 for the Asstt.Year 2007-08. 2. Though the assessee has taken four grounds of appeal, but its grievances revolve around a single issue, whereby, it has pleaded that the ld.CIT has erred in taking cognizance under section 263 of the Income Tax Act and setting aside the assessment order passed on 20.12.2010 under section 143(3) of the Act and directing the AO to make fresh assessment. 3. Brief facts of the case are that the assessee-company has fi .....

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able by the assessee under section 115JB of the Income Tax Act at ₹ 74,82,453/-. 4. On scrutiny of the record, the ld.Commissioenr harboured a belief that the assessment order is erroneous and prejudicial to the interest of the Revenue, which required revision under section 263 of the Income Tax Act. Accordingly, she has recorded reasons for taking action under section 263 of the Income Tax Act. Copy of the show cause notice issued under section 263 dated 12.3.2013 is available on page no. .....

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On receipt of notice, the assessee has made elaborate submissions. The copy of the submissions has been placed on record at page nos.3 to 14 of the paper book. The ld.Commissioner somehow did not concur with the submissions of the assessee and in a brief order treated the assessment order as erroneous and prejudicial to the interest of the Revenue. The finding record by the ld.Commissioner read as under: "3. The brief facts of the case are that the assessee filed its return of income for A. .....

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der the West Bengal Incentive Scheme, 2000. Further, the assessee had claimed ₹ 222.64 lakhs as currency swap loss and treated the same as business loss although it was in the nature of speculation loss. 5. Regarding the first issue, it was submitted that the assessee had accounted for the Industrial Promotion Assistance receivable from the Government of West Bengal on accrual basis in the current year. Subsequently, in the assessment year 2008-09, company's right to recover this incen .....

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However, this was not verified by the Assessing Officer while finalizing the assess- en: under Section 143(3) of the Act. The claim of assessee that such amount has ultimately become unrealizable in A.Y. 2008-09 and written off as bad debt in that assessment year was also not verified by the AO while passing the order. Lack of enquiry renders the order of assessment erroneous and prejudicial to the interests of revenue. Lack of enquiry could include not only a situation where no enquiry was made .....

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arried out either by way of forward contracts or options, depending on the prevailing market conditions, with a view to protecting itself from the losses that may arise on account of adverse fluctuations in the foreign exchange rate. It was also submitted that provisions of Section 43(5) apply to transactions in which a contract for the purchase or sale of commodity including stocks and shares which is periodically or ultimately settled otherwise than by the actual delivery or transfer of the co .....

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and whether the loss arising from such transactions is business loss or speculative loss. Further, applicability of provisions of Section 43(5) including its proviso ie., 43(5)(d), which deals with an eligible transaction in respect of transaction in derivatives, has not been examined by the Assessing Officer. The assessee has claimed substantial loss and same has been allowed without proper verification. On this account also, the impugned order of the AO is unsustainable in the eyes of law. 9. .....

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filed statement of facts running into 27 pages. On page nos.4 to 10 of the statement of facts, the assessee has explained its position with regard to both these issues, which has not been considered in detail by the ld.Commissioner. In order to appreciate the controversy in right perspective and with a view to avoid repetition, we deem it appropriate to take note of the submission made by the assessee in the statement of facts starting from page nos.4 to 10 (relevant part). It reads as under: &q .....

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mpany is eligible for following assistance: a) Industrial Promotion Assistance As per the scheme, 75% of sales tax paid in immediately preceding year, is available as an incentive, in subsequent year. Such incentive is to be paid through a cheque to be deposited through a challan as an advance tax. As per the condition of the scheme, the incentive is available up to 100% of Fixed Capital Investment or upto completion of 15 years, whichever is earlier. b) State Capital Investment subsidy As per t .....

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profit and loss account as is evident on perusal of Schedule-12 under the head "Other Govt. Incentives". However, in the A.Y.2008-09, the right to recover the same incentive is impaired on account of non filing of application for incentive which was one of the conditions for getting the IPA incentive. This is evident on perusal of note no 17(b) of the Audited Annual Report. Since, the incentive is not receivable due to procedural lapse, the company has, while filing return of income fo .....

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he real income has not been realized and received by the assessee and therefore the assessee is not liable to treat the same as income. 2.2 However, on account of procedural lapse by the company, now the company is not eligible for this incentive income for the A.Y.2008-09 and hence, the IPA incentive income is reversed in the A.Y.2008-09. To nullify the said effect, the company has deducted IPA incentive originally considered as income in the A.Y. 2007-08 and disallowed the same in the A.Y.2008 .....

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aid factual position was fully explained in the written reply. This factual position proves that in the ultimate analysis incentive receivable at ₹ 5,44,24,167 has not at all accrued to the assessee-company and, therefore, the aforesaid amount was not assessable at all. The accounting entries passed by the assessee-company are in consonance with the mercantile system of accounting followed by the assessee. After considering the written submissions, the Assessing Officer adopted a correct v .....

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Swap (Loss)/Gain. In this regard we submit that the company has incurred currency swap loss of ₹ 2,22,63,965 on account of repayment of Foreign Currency denominated loan taken by swapping US $ liability into Rupees terms. On perusal of schedule-3 of the Audited Annual Report, your goodself would find that the outstanding balance of FCNR loan as on 31st March, 2006 of ₹ 9.15 crores is reduced to ₹ 5.32 crores as on 31st March, 2007. We are submitting herewith the complete detail .....

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t was pointed out that the regular business activity of the assessee-company involves substantial imports and exports. Accordingly, in the interest of business the assessee-company entered into the currency swap contract of underlying rupees loan into dollar loan with HDFC bank and SCB Bank. On maturity of the aforesaid swap contract the assessee sold dollar loan to get back the underlying rupee loan and by this transaction the assessee incurred a loss of ₹ 2,22,63,965. It was explained be .....

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forcefully explained to the learned CIT that, having regard to the correct factual and the legal position, the loss arising from the aforesaid swapping transaction cannot be treated as speculation loss on the ground that the same is not excluded under clause (d) of section 43(5) of the I.T. Act. The learned CIT summarily rejected these submissions and assumed that the Assessing Officer failed to verify this relevant issue and on that account the order passed by him is erroneous. He relied on the .....

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section 43(5) are reproduced below with emphasis supplied: "(5) "speculative transaction" means a transaction in which a contract for the purchase or sale of any commodity, including stocks and shares, is periodically or ultimately settled otherwise than by the actual delivery or transfer of the commodity or scrips: Provided that for the purposes of this clause- (a) a contract in respect of raw materials or merchandise entered into by a person in the course of his manufacturing or .....

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bbing or arbitrage to guard against loss which may arise in the ordinary course of his business as such member; o] (d) an eligible transaction in respect of trading in derivatives referred to in clause 35[(ac)] of section 236 of the Securities Contracts (Regulation) Act, 1956 (42 of 1956) carried out in a recognised stock exchange;] shall not be deemed to be a speculative transaction. Explanation.- For the purposes of this clause, the expressions- (i) "eligible transaction" means any t .....

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ued under those Acts or by banks or mutual funds on a recognised stock exchange; and (B) which is supported by a time stamped contract note issued by such stock broker or sub-broker or such other intermediary to every client indicating in the contract note the unique client identity number allotted under any Act referred to in sub-clause (A) and permanent account number allotted under this Act; (ii) "recognised stock exchange" means a recognised stock exchange as referred to in clause .....

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the commodity or scrips. It was explained that the word "commodity", by no stretch of imagination, can cover currency which is only a medium of exchange with which goods and services can be bought and sold. It was further pointed out that the Legislature, while enacting the aforesaid provision, thought it necessary to expressly include stocks and shares as being covered under "commodity", which means that but for such expressed inclusion, the word "commodity" would .....

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acts in respect of currencies whereas it specially covers raw-material, merchandise, stock and shares. This further confirms that the Legislature was clear in its mind that since the word "commodity" itself cannot take in any currency as such, there can be no question for providing an inception in that regard in the proviso." 7. The ld.counsel for the assessee while impugning the order of the CIT(A) has raised two fold submissions. In the first fold of his submissions, he submitte .....

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it could be inferred that the assessment order has been passed after going through all the relevant material. In order to buttress this contention, he took us through the questionnaire issued by the AO whose copies available on page no.36 of the paper book. He drew our attention towards the questions raised at Sr.Nos.36, 40 and 48. The assessee has given a reply to this questionnaire running into 45 pages, which is also been placed on page nos.42 to 97 of the paper book. On the strength of these .....

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assessee on accrual basis, but realizing the fact that this income is not going to be materialized, therefore, it was reduced from the return. The assessee has first shown the income in the Asstt.Year 2007-08 and claimed the deduction in the Asstt.Year 2008-09. However, subsequently, the assessee has revised the return for the Asstt.Year 2007-08 and reduced the income earlier shown on accrual basis, meaning thereby, the deduction claimed in the subsequent year is again added back. There was no i .....

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fluctuations. This issue has been considered in the case of Adani Enterprises Ltd. for the Asstt.Year 2007-08 as well as Astt.Year 2008-09. On the strength of the Hon'ble Gujarat High Court in the case of CIT Vs. Friends and Friends Shipping P. Ltd., 35 taxmann.com 553 (Guj), the Tribunal has upheld the action of the AO of allowing this loss as business loss. He placed on record. Hon'ble Gujarat High Court decision in the case of CIT Vs. Friends and Friends Shipping P. Ltd. (supra). Thus .....

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ntentions and gone through the record carefully. Section 263 has a direct bearing on the controversy, therefore, it is pertinent to take note of this section. It reads as under:- "263(1) The Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer is erroneous in so far as it is prejudicial to the interest of the revenue, he may, after giving the assessee an opportunity of being heard and af .....

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made by the Assistant Commissioner or Deputy Commissioner or the Incometax Officer on the basis of the directions issued by the Joint Commissioner under section 144A; (ii) an order made by the Joint Commissioner in exercise of the powers or in the performance of the functions of an Assessing Officer conferred on, or assigned to, him under the orders or directions issued by the Board or by the Chief Commissioner or Director General or Commissioner authorized by the Board in this behalf under sect .....

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matters as had not been considered and decided in such appeal. (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section (2), an order in revision under this section may be passed at any time in the case of an order which has been passed in consequence of, or to give effect to, any finding or direction contained in an order of the Appel .....

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n 263 to the learned Commissioner have four compartments. In the first place, the learned Commissioner may call for and examine the records of any proceedings under this Act. For calling of the record and examination, the learned Commissioner was not required to show any reason. It is a part of his administrative control to call for the records and examine them. The second feature would come when he will judge an order passed by an Assessing Officer on culmination of any proceedings or during th .....

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d on a particular order of the Assessing Officer. At this stage the opportunity to the assessee would be given. The learned Commissioner has to conduct an inquiry as he may deem fit. After hearing the assessee, he will pass the order. This is the 4th compartment of this section. The learned Commissioner may annul the order of the Assessing Officer. He may enhance the assessed income by modifying the order. At this stage, before considering the multi-fold contentions of the ld. Representatives, w .....

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st record satisfaction that the order of the AO is erroneous and prejudicial to the interest of the Revenue. Both the conditions must be fulfilled. (ii) Sec. 263 cannot be invoked to correct each and every type of mistake or error committed by the AO and it was only when an order is erroneous that the section will be attracted. (iii) An incorrect assumption of facts or an incorrect application of law will suffice the requirement of order being erroneous. (iv) If the order is passed without appli .....

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makes enquiries, applies his mind to the facts and circumstances of the case and determine the income, the CIT, while exercising his power under s 263 is not permitted to substitute his estimate of income in place of the income estimated by the AO. (vii) The AO exercises quasi-judicial power vested in his and if he exercises such power in accordance with law and arrive at a conclusion, such conclusion cannot be termed to be erroneous simply because the CIT does not fee stratified with the concl .....

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scussion in that regard. 13. Apart from the above principles, we deem it appropriate to make reference to the decision of the Hon'ble Delhi High Court in the case of CIT vs. Sun Beam Auto reported in 227 CTR 113 referred by ld. Counsel for the assessee, and Gee Vee Enterprises Ltd vs. Addl. Commissioner of Income Tax (99 ITR 375). In the case of Sun Beam Auto, the Hon'ble High Court has pointed out a distinction between lack of inquiry and inadequate inquiry. If there is a lack of enquir .....

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ing the assessment order, the Assessing Officer did not consider this aspect specifically whether the expenditure in question was revenue or capital expenditure. This argument predicates on the assessment order which apparently does not give any reasons while allowing the entire expenditure as revenue expenditure. However, that by itself would not be indicative of the fact that the Assessing Officer had not applied his mind on the issue. There are judgments galore laying down the principle that .....

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inadequate, that would not by itself, give occasion to the Commissioner to pass orders under section 263 of the Act, merely because he has different opinion in the matter. It is only in cases of "lack of inquiry", that such a course of action would be open". 14. In the case of Gee Vee Enterprise vs. Commissioner of Income Tax reported in 99 ITR page 375, the Hon'ble court has expounded the approach of ld. Assessing Officer while passing assessment order. The observation of th .....

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Officer is very diffident from that of a civil court. The statement made in a pleading proved by the minimum amount of evidence may be adopted by a civil court in the absence of any rebuttal. The civil court is neutral. It simply gives decision on the basis of the pleading and evidence which comes before it. The Income-tax Officer is not only on adjudicator but also an investigator. He cannot remain passive in the face of the return which is apparently in order but called for further inquiry. I .....

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thing wrong with the order if all the facts stated therein are assumed to be correct." 15. The Hon'ble Gujarat High Court in the case of Amit Corporation (supra) has observed as under: "5. We are of the opinion that the Tribunal committed no error. When, during the course of framing of the assessment, the Assessing Officer had access to all the records of the assessee, after pursuing such record the Assessing Officer framed the assessment, such assessment could not have been re-ope .....

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t;36. Pl. provide complete details of currency swap (loss/gain) ….. 40. Pl. provide details of grants /subsidy sanctioned/received during the year along with details of its accounting treatment. …. 48. With regard to reversal of income from Target Plus Scheme amounting to ₹ 43.41 Million (entry 17(a) - Notes of Accounts), pl. provide complete details along with working and copy of Government Notification No08/2006 dt.12/06/2006. Further, reconcile the same with the amount red .....

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