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2016 (7) TMI 165 - ITAT HYDERABAD

2016 (7) TMI 165 - ITAT HYDERABAD - TMI - TDS u/s 195 - Disallowance of claim of interest paid on Foreign Currency Convertible Bonds (FCCB) for non deduction of TDS - Held that:- Not only the bonds were raised outside India, but the interest payments were also made to non-resident Indians outside India from a bank account held by the assessee outside India. Therefore, since no part of the transaction relating to payment of interest has taken place in India, it cannot be said that interest paymen .....

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- Decided in favour of assessee - Restriction on claim of depreciation u/s 32 - Held that:- In the present case, the subsidy was issued in reference to the machinery. Assessee submitted letter of approval of subsidy but from that letter it could not be established whether the subsidy was issued for the benefit of business or for the expansion of business. Moreover, the letter of approval was addressed to VVS Pharmaceuticals & Chemicals Pvt. Ltd., which is the previous name of the assessee, a .....

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e made before filing of return of income. The Hon’ble Supreme Court in the case of CIT Vs. Alom Extrusions Ltd. [2009 (11) TMI 27 - SUPREME COURT ] held that the amendments to section 43B brought out by the Finance Act, 2003 with effect from 01/04/2004 are retrospective in nature and would operate from 01/04/1988. Various benches of ITAT and coordinate benches of this Tribunal have followed the above decision and held that the amendment to section 43B brought out by the Finance Act, 2003 is retr .....

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no order of approval of DSIR containing the quantification of the expenditure entitled for deduction u/s 35(2AB) of the Act, has been submitted by the assessee. Even before us, assessee had not submitted any records, which is required as per section 35(2AB)(3) but contested that all the relevant approvals were submitted. We remit the issue back to the file of the AO to verify the approval of quantification by the DSIR along with the audited financial records. Assessee may be given proper opport .....

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ich was allowed u/s 37 as deduction. But, in the present case, disallowance was made due to non filing of proof of payment. We remit this issue back to the file of the AO to verify the proof of payment as claimed by the assessee on payment of gratuity and leave encashment. If found proper, he may allow this expenditure, otherwise, the disallowance may be sustained. Assessee may be given proper opportunity of being heard - Disallowance of the claim of Foreign exchange fluctuation - Held that: .....

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period in which they arise. An enterprise has to report the outstanding liability relating to import of raw-material using closing rate or exchange and the same has to be recognized in the prof it & loss account for the reporting period. Hence, the same may be allowed. - Revision u/s 263 - Held that:- CIT re-examined the issues which are already considered by AO during the assessment proceedings. Since AO already considered and taken a stand and formed an opinion, may be a possible view at t .....

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the opinion that CIT cannot review the order of AO, who has applied his mind on the issues which are subject matter of dispute now. Hence we quash this order of CIT passed u/s 263 of the Act. - ITA No. 508/Hyd/2012, ITA No. 1041/Hyd/2013 - Dated:- 31-5-2016 - Smt P. Madhavi Devi, Judicial Member And Shri S. Rifaur Rahman, Accountant Member For the Assessee : Shri P. Murali Mohan Rao For the Revenue : Shri R. B. Naik ORDER Per S. Rifaur Rahman, A. M. ITA No. 508/Hyd/2012 by the assessee This app .....

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by making following disallowances: a) Disallowance of claim of interest of ₹ 57,98,000/- on foreign currency convertible bonds (FCCB). b) Restriction of claim of Bank interest and finance charges by ₹ 30,10,000/- c) Disallowance of depreciation u/s 32(1) of ₹ 4,46,501/-. d) Addition for delayed remittance of ESI ₹ 42,086/-. e) Disallowance of scientific research expenditure claimed u/s 35(2AB) of ₹ 89,86,705/-. f) Disallowance u/s 40(a)(ia), ₹ 1,00,000/-. g) D .....

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Court s decision in the case of CIT Vs. AIMIL Ltd., 321 ITR 508. 4. Aggrieved with the above order, assessee is in appeal before us and has raised the following grounds of appeal: The Honourable Commissioner of Income Tax(Appeals) - IV, Hyderabad erred while passing the order in respect of MIS. VIVIMED LABS LIMITED, for the Assessment Year 2008-09 where in, it was held that the assessment order passed by the assessing officer u/s 143(3) dated 30/12/2010 The following are the Grounds of Appeal wh .....

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for the said interest. The Assessing Officer, while passing the Order, disallowed the claim of interest on Foreign Currency Convertible Bonds of ₹ 57,98,000/- on the contention that TDS required u/s. 195 of the Income Tax Act, 1961 has not been deducted. We would like to submit that, Citi Bank Singapore had debited ale with interest, Bank Charges during the year and the same were accounted under "Interest & Financial Charges" and the question of this does not arise on Bank I .....

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)(iii): The CIT(Appeal)-IV erred while passing order, where in confirmed the order of the assessing officer with the contention that, charging interest @ 12% BPLR on the investment shown at ₹ 2,50,51,000/- which works out to ₹ 30,18,000/-. The CIT(Appeal)-IV erred while passing order, where in confirmed the order of the assessing officer towards addition o fRs. 30,18,000/- as the claim of Bank interest & Financial charges proportionate to investments made in Creative Care Health .....

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is out of the accruals of the Company. In view of the above explanation, the charging of interest is not in order and invalid. 4. Disallowance of depreciation u/s. 32 on the amount received as Central Investment Subsidy: The CIT(Appeal)-IV erred while passing order, where in confirmed the order of the assessing officer, while reducing the amount of subsidy while allowance of depreciation which is not correct and justified in law. As the amount has already been included in Block of Assets being .....

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wing total claim of ₹ 89,86,705/- towards expenditure on scientific research. The Assessing Officer, while passing the Order, disallowed the claim of expenditure on scientific research of ₹ 89,86, 705/-. The Assessing Officer contended that during the course of scrutiny proceedings, the Assessee Company has been required to furnish the quantum of expenditure approved by the prescribed authority for the assessment year under consideration for the allowance of its claim. We would like .....

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sessing Officer, while passing the Order, disallowed remuneration paid to auditors ₹ 1,00,000/- contending that expenditure claimed towards auditors remuneration paid is without deducting TDS. We would like to submit that, TDS is deducted from the remuneration paid to the auditors and detail of the amount of TDS deducted and other details are also submitted. 7. Disallowance of the provision made towards liability Viz. (i) Gratuity and (ii) Leave Encashment: The CIT(Appeal)-IV erred while p .....

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ssee, the actual payment is also made in the same year. The details of payments are also enclosed. In view of the above explanation, the provision made during the year is though is allowed u/s. 40A(7), if same is paid during the year the amount is not allowed as expenditure deductible as expenses. 8. Disallowance of the claim of "Fluctuation in Foreign Exchange" The CIT(Appeal)-IV erred while passing order, where in confirmed the order of the assessing officer while disallowing claim o .....

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in confirmed the contention of the assessing officer that the assessee should furnish details as to whether the forex loss is on account of revenue or capital. We would like to submit that the amount of ₹ 21,48,000/- is allowed u/s. 37(1) as amount is related to the payment made to the creditors and thus be allowed on revenue account and is not related to purchase of machinery etc., which could be disallowed on capital account. In view of the above explanation, the "Fluctuation in Fo .....

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ted that similar addition was made in AY 2009-10 in assessee s own case. The coordinate bench of this Tribunal has deleted the addition made. He has submitted the relevant decision in his paper book. He prayed that the disallowance made in the AY under consideration should also be deleted by following the above decision. iii) Ld. DR relied on the orders of AO & CIT(A) and submitted that it may be remitted back to the file of the AO to re-examine the loan agreement and terms of sanction of th .....

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into equity shares or claim repayment after five years. The bonds were raised in the financial year 2007-08 with interest rate of 1% per annum. It is the claim of the assessee that not only the bonds were raised from international market, but the payments were also sourced from assessee s bank account abroad. Therefore, the provisions of S.195 could not be applied. On a perusal of the assessment order and the order of the first appellate authority, it is seen that the only reason on which the de .....

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but the interest payments were also made to non-resident Indians outside India from a bank account held by the assessee outside India. Therefore, since no part of the transaction relating to payment of interest has taken place in India, it cannot be said that interest payment made to non-residents has accrued or arisen in India in terms of S.9 of the Act. In our view, therefore, the provisions of S.195 would not apply to such payments, thereby requiring the assessee to deduct tax at source. We a .....

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d the income derived therefrom is exempt from tax. At the same time, assessee claims expenditure of bank interest and financial charges, but, no explanation was offered as to the investments were out of commercial expediency. AO opined that assessee has secured loans and unsecured loans, had the monies invested in equities been utilized for business purposes, assessee s burden of bank interest should have been reduced to that extent. Accordingly, he had restricted by an amount of ₹ 30,18,0 .....

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paper book). iii) Ld. DR relied on the orders of the lower authorities. iv) Considering the submissions of both the counsels and material facts on record and relevant decision of this Tribunal, we find that the coordinate bench has given clear findings on this issue, for the sake of clarity, we reproduce the same below: 18. We have considered the submissions of the parties and perused the material on record. It is relevant to note that right from the assessment stage, it is the plea of the asse .....

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icient interest free fund was available with the assessee to make the investment in equity shares of the two companies. Hon'ble Bombay High Court in the case of C.I.T. vs. Reliance Utilities & Power Ltd., (2009) 313 ITR 340 (Bom.) has held that when the assessee has mixed funds, i.e. both interest free and interest bearing funds, presumption would be interest free advances are from interest free funds available with the assessee. Applying the same principle, it has to be held that the in .....

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y made. In view of the aforesaid factual position, we hold that the disallowance of interest expenditure amounting to ₹ 17,85,000/- is not sustainable. Accordingly, we delete the same, allowing the grounds of the assessee on this issue. Respectfully following the decision of the coordinate bench, we delete the addition made. C) Restriction on claim of depreciation u/s 32: i) The AO noted that the assessee company was sanctioned a subsidy of ₹ 29,76,676/- under the 15 percent central .....

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so allowed will go on to reduce the cost of acquisition of the assets for the purpose of claiming depreciation u/s 32 of the IT Act. The assessee, however, did not reduce the investment subsidy from the cost of the relevant assets, before claiming depreciation for the AY 2008-09. The subsidy of ₹ 29,76,676/- is to be rightly treated on capital account and hence, the same is reduced from the value of additions to assets during the year to determine the depreciation allowable. Accordingly, t .....

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High Court in the case of CIT Vs. Godavari Plywoods Ltd., 168 ITR 632 (A). iii) Ld. DR relied on the orders of the lower authorities. iv) Considering the submissions and material facts on record as well as perusing the Hon ble Supreme Court s decision in the case of P.J. Chemicals, it had accepted the majority views of the different High Courts, in particular, the views of Hon ble High Court of P&H in the case of CIT Vs. Jindal Bros. Rice Mills, [1989] 179 ITR 470. The respective ratio of th .....

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ard areas and establish industries, the specified percentage of the fixed capital cost which is the basis for determining the subsidy being only a measure adopted under the scheme to quantify the financial aid. The contention is that it is not a payment, directly or indirectly, to meet any portion of the "actual cost" but intended as an incentive to entrepreneurs, its quantification determined at a percentage of the fixed capital cost. In Godavary Plywoods' case (supra), the Andhra .....

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o depreciation was admissible or on plant and machinery or for erection of buildings or for working capital or for repaying the loans already borrowed. Hence, unless the subsidy received had a nexus, direct or indirect, to meet a portion of the actual cost of any specific capital asset. it could not be brought within the purview of s. 43(1) of the Act. Therefore, the subsidy could not be deducted from the actual cost of the assets to the assessee and depreciation should be allowed without reduci .....

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s and specified a certain percentage of the amount so invested in the capital assets as cash subsidy. The basis adopted for determining the cash subsidy with reference to the cost or value of fixed assets was only a measure for quantifying the subsidy and the subsidy was not given for the specific purpose of meeting any portion of the cost of the fixed assets. Consequently, the subsidy did not form part of the actual cost of plant and machinery within the meaning of s. 43 of the IT Act, 1961. It .....

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achinery and building by 15 per cent of the actual cost. The actual cost would so stand reduced within the meaning of s. 43(1) of the Act.... We are equally not impressed by the reasoning that the basis adopted for determining the cash subsidy with reference to the fixed capital cost is only a measure adopted and cannot make the subsidy as given only for the specific purpose of meeting any portion of the fixed capital cost..... The incentive by way of subsidy is given for each item separately an .....

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ubsidy under each head." 15. On a consideration of the matter the view that commends itself as acceptable is the one which has commended itself to the majority of the High Courts. It is, of course, not the numerical strength that prevails - though the fact that a particular view has commended itself to a majority of the High Courts in the country is a matter for consideration - but the tensile strength of the acceptable logic in those decisions. It is aptly said that "a Judge who annou .....

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needs to be interpreted liberally. The subsidy of the nature, we are concerned with, does not partake of the incidents which attract the conditions for their deductibility from "actual cost". Government subsidy, it is not unreasonable to say, is an incentive not for the specific purpose of meeting a portion of the cost of the assets, though quantified as or geared to a percentage of such cost. If that be so, it does not partake of the character of a payment intended either directly or .....

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e Supreme Court had dismissed the appeal of the revenue and upheld that the determination of the subsidy is linked to the specif ic assets but subsidy issued for the overall benef it of the business. In the present case, the subsidy was issued in reference to the machinery. But, the assessee had submitted the letter of approval of subsidy but from that letter it could not be established whether the subsidy was issued for the benef it of the business or for the expansion of the business. Moreover .....

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of being heard. In the result, this ground is allowed for statistical purposes. D) Addition on account of delay in payment of PF & ESI: i) AO disallowed the PF & ESI as the assessee made remittance of the amounts after due date, by virtue of insertion of clause (i) of subsection( 24) of section 2 by Finance Act, 1987, even the employees contribution to PF and subscription to insurance etc., are required to be included within the income of the assessee. ii) Ld. AR submitted that all the r .....

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[2009] 319 ITR 306 (SC) held that the amendments to section 43B brought out by the Finance Act, 2003 with effect from 01/04/2004 are retrospective in nature and would operate from 01/04/1988. Various benches of ITAT and coordinate benches of this Tribunal have followed the above decision and held that the amendment to section 43B brought out by the Finance Act, 2003 is retrospective in nature and justified in deleting the additions made on account of delayed payment of Provident Fund of employee .....

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y filed letter No. TU/IV-RD/2509/2005, dt. 27/06/2006 wherein the recognition of Inhouse R&D unit of the assessee company was confirmed by the Department of Science and Industrial Research (DSIR), Ministry of Science and Technology, Govt. of India. However, the assessee furnished no order of approval issued by DSIR containing the quantum of expenditure approved, eligible for deduction. ii) The AO noted that as per clause (3) of sub-section (2AB) of section 35, the assessee shall be entitled .....

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the weighted deduction claimed at ₹ 89,86,705/-. iii) Ld. AR submitted that assessee is having necessary approval from DSIR and addition cannot be sustained. He also submitted that similar disallowance was made in AY 2009-10 and the coordinate bench has remitted back the issue to the file of the AO to verify the approval and allow the deduction found correct. iv) He also submitted that DSIR has accorded approval vide in its letter received (refer pages 7-8 of paper book) and he also submit .....

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e us, assessee had not submitted any records, which is required as per sub-section (3) of section 35(2AB) of the Act but contested that all the relevant approvals were submitted. We remit the issue back to the file of the AO to verify the approval of quantification by the DSIR along with the audited financial records. Assessee may be given proper opportunity of being heard. vii) In the result, this ground of assessee is allowed for statistical purposes. F) Disallowance u/s 40(a)(ia) i) Since the .....

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different from regular assessment u/s 143(3) of the Act. It is not practicable to initiate proceedings u/s 201(1). If the assessee fails to deduct tax, particular expenditure has to be disallowed u/s 40(a)(ia). He insisted that this issue may be remitted back to the file of the AO for verification. iv) Considering the submissions of the parties and material facts on record, we find that the coordinate bench of this Tribunal has remitted similar issue back to the file of the AO to verify as to w .....

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le of the AO to verify as to whether the assessee is treated as an assessee in default u/s 201(1) of the Act with regard to payment of audit fees. If it is found on such verification that the assessee is not in default, AO is directed to delete the disallowance made u/s 40(a)(ia) on account of audit fees. In the result, this ground of appeal is allowed for statistical purposes. G) Disallowance of provision of Gratuity: i) The assessee made provisions towards payment of gratuity and leave encashm .....

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nsidering the submissions of the parties and material facts on record, we find that the AO had made addition due to non-submission of proof for payment made on gratuity and leave encashment. Ld. AR submits that the payments were made. Ld. AR relied on the case of Sri Krishna Pharmaceuticals. On perusal of order, we find that the facts of this case are different. The disallowance was made due to creation of unrecognized gratuity fund, which was allowed u/s 37 as deduction. But, in the present cas .....

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ssee debited to profit & loss account an amount of ₹ 21,48,000/- towards fluctuation in foreign exchange. When AO asked to explain as to how the claim of fluctuation in foreign exchange is allowable u/s 37(1) of the Act, the assessee has not furnished any details as to whether the forex loss is on revenue account or capital account or deferment of repayment of loan. ii) The AO observed that the IT Act contemplates taxing only real income and real losses and no notional income and notio .....

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expenditure is what is paid out and something which is gone irretrievable. AO noted that increase in liability at any point of time prior to payment cannot fall within the meaning of the word expenditure in section 37(1). He observed that the requirement of expenditure is not met and similarly the requirement of money being expended or laid out is also not satisfied. AO, therefore, disallowed the assessee s claim of fluctuation in foreign exchange at ₹ 21,48,000/- and added the same to th .....

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e case of CIT Vs. Woodword Governer India Pvt. Ltd, 312 ITR 254(SC) where it is held as under:- Where it has been held that loss suffered by the assessee in respect of revenue liabil ity on account of exchange difference as on the date of the Balance Sheet is an item of expenditure allowable under section 37(1). As per AS 11, exchange difference arising on foreign currency transactions have to be recognized as income or expense in the period in which they arise. An enterprise has to report the o .....

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as filed its return of income for AY 2008-09 electronically on 26.09.2008 admitting total income of ₹ 5,41,18,320/-. The case was selected for regular assessment and AO completed the assessment u/s 143(3) and determined the taxable income at ₹ 7,63,19,612/- The CIT-III by virtue of power vested on him u/s 263 has called for and examined the assessment records and found that following issues were not examined by the AO in the assessment proceedings: i) Sales Tax penalty of ₹ 12, .....

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im is not sub-judice before hon ble ITAT. He also noticed that AO has while completing the assessment u/s 143(3) has erroneously failed to examine the above said issues and its tax implications. Therefore, the above issues were not on the record and not placed in the assessment order. Hence, CIT has power to revise the assessment u/s 263 of the Act. He considered the assessment passed u/s 143(3) of the Act as erroneous and so far as it is prejudicial to the interest of revenue. 10. Ld AR submitt .....

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/s 263 observing that the assessment order passed u/s.143(3) by the DCIT, Circle-3(3), Hyderabad is erroneous and prejudicial to the interests of revenue. 3. The Ld. CIT-III, Hyderabad erred in passing the order U/s.263 by forming mere change of opinion and without considering the fact that the original assessment had been completed u/s 143(3) of the IT Act, 1961 after careful verification of all the information furnished. 4. The Ld. CIT-III, Hyderabad ought to have appreciated the judgment of H .....

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e depreciation of ₹ 7,59,65,617/- on pollution control equipment. 8. The Ld. CIT-III, Hyderabad erred in directing the AO to disallow deprecation on pollution control equipment which was already examined and allowed by the AO u/s143(3) of the IT Act,1961. 13. Ld AR Submitted before us the correspondence exchanged with AO during assessment proceedings, which are submitted along with the paper book, refer pages 30 to 59 of the paper book. He submitted that AO had already considered the issue .....

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case. 14. Ld DR relies on the order of CIT. 15. Considered the submissions of both counsels and material facts on record. We are of the view that CIT-III re-examined the issues which are already considered by AO during the assessment proceedings. Since AO already considered and taken a stand and formed an opinion, may be a possible view at that point of time, passed the assessment order based on the above opinion. The CIT-III cannot exercise the revisional jurisdictional power on the same issue .....

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