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2019 (5) TMI 429

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..... stinct transactions; one involving the shares which the assessee issued to twenty two share subscribing companies and another involving sale of investments which the assessee held in other bodies corporate. It may be so that Shri Mahavar or companies managed by him were connected with both the set of transactions. However both the sets of transactions were separate from each other and consequences flowing from these sets of transactions were also separate and could not be intermixed. In the reasons the AO recorded his satisfaction about escapement of income specifically with reference to assessee’s transactions involving sale of investments totaling ₹ 34 Crs. The satisfaction recorded did not any manner suggest that in AO’s opinion share subscription amount of ₹ 30.20 Crs. received during the year from 22 subscribers represented assessee’s income escaping assessment. We therefore concur with the findings of the Ld. CIT(A) that no addition was made in the order u/s 147/143(3) dated 31.03.2016 with reference to the reasons for which the assessment was reopened and in that view of the matter the impugned order u/s 147/143(3) is held to be legally unsus .....

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..... e assessed as it s income u/s 68 of the Act for the AY 2010-11. In response the assessee furnished its rebuttal, which is placed at Pages 17 to 22 of the paper book. The AO ultimately completed the assessment u/s 147/143(3) on 30.03.2016 assesssing ₹ 30.20 crores as unexplained cash credit u/s 68 being the amount received as share subscription for shares issued during the relevant year. Aggrieved by the order the assessee preferred appeal before the Ld. CIT(A) challenging the legal validity of the assessment completed u/s 147/143(3) as also the merits of the addition u/s 68 of the Act. The Ld. CIT(A) found merit in the assessee s initial plea that when the AO reopened the assessment after recording specific reasons but in assessment order no addition was ultimately made with reference to the specific issue for which the assessment was reopened, then the consequent assessment order was legally unsustainable. The relevant findings of the Ld. CIT(A) were as follows: 4.5 From bare perusal of the reasons recorded it is apparent that based on the information provided by the Investigation wing of the Income-tax Department the AO had formed a belief that the assessee s investments wo .....

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..... the assessee s bank account in the form of proceeds of sale of shares represented assessee s income which had escaped assessment in AY 2010-11. 4.6 On scrutiny of the impugned order u/s 143(3)/147, I however find that in the course of reassessment proceedings the AO conducted enquiry only with regard to shares which the assessee issued at premium during FY 2009-10 to 22 bodies corporate from whom it received ₹ 30.20 crores. Although in the impugned order the AO has extensively extracted the statements which the Investigation Officers of the Department had recorded in the course of survey u/s 133A and thereafter u/s131 from Shri Mahawar and his associates yet ultimately the AO confined his enquiry and his findings with regard to the issue of taxability of share subscription amounts received from 22 bodies corporate. After setting out extensively the statements of Shri Mahawar and others the AO claimed that in view of the findings made during the course of reassessment and findings made during the course of survey the assessee had failed to prove the identity, genuineness and creditworthiness of the shareholders from which share capital along with premium amounting to ₹ 3 .....

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..... he appellant s case I find that it has been unanimously held that an AO can proceed to make additions in the order u/s 147 to the earlier assessed income if and only if the addition is first made by the AO with reference to the grounds or issue for which reason is recorded u/s 148(2) of the Act. Where however no addition is made in the order u/s 147 with reference to the reason recorded u/s 148 or where the addition made with reference to the reasons recorded is deleted by the appellate authority then the only course open to the appellate authority is to cancel the entire re-assessment since the very rationale for initiation of the reassessment proceedings stands invalidated once no addition in respect of recorded reason survives. The unanimity of the view in all these decisions is that the AO cannot travel beyond the recorded reasons and make additions with regard to other issues if no addition is made or no addition is found sustainable with reference to the recorded reasons before initiation of reassessment proceedings. Such action is permissible if any only if the AO in the first instance justifies the addition to the last assessed income with reference to reasons recorded u/s .....

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..... es is to quash the reassessment. I order accordingly. Ground Nos. 1 & 2 are therefore allowed. 4. Since the Ld. CIT(A) upheld the assessee s preliminary challenge to the validity of the order passed u/s 147/143(3), he did not adjudicate the assessee s grounds involving merits of the addition made by the AO. Being aggrieved by the order of the Ld. CIT(A), the Revenue is now in appeal raising the following grounds :- 1. That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in fact and in law in accepting assessee s contention that addition was not made on the basis of which the case was reopened. 2. That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in holding that no addition can be made on any ground other than those on the basis of which the case was re-opened. 5. We have heard the rival submissions and considered factual matrix involved in the present case. Assailing the action of the Ld. CIT(A) quashing the reassessment order, the Ld. DR appearing on behalf of the Revenue submitted that in his recorded reasons the AO had made reference to the material fact that during the relevant previous year the assessee had raised .....

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..... ued at a premium of ₹ 90/- per share and on paper ₹ 3.56 crore was raised. This was again only on paper as the subscribers were only other paper companies of Shri Mahawar and the subscription was through circular transactions. In March, 2010 again 12,08,000 shares of FV ₹ 10 were issued at a premium of ₹ 240/- per share and nearly ₹ 31 Crore was raised by the same modus operandi. After this issue the net worth of the company became ₹ 34.52 Crores. Thereafter, in March, 2010 Shri Mahawar sold this company to the RPG group and Shri Rajendra Jha and Shri Sunil Bhandari who are the employee of the RPG Group become the directors of M/s. Dotex Merchandise Pvt Ltd. It is also found that from 12/10/2011 to 28/03/2013 Shri R. P. Goenka himself was the director of this company. After RPG group purchased this company, entire share holding was bought back by two companies of RPG namely, Solty Commercial Pvt Ltd and Ritushri Vanijya Pvt Ltd. As expected after the purchase by Sanjeev RPG group, the investment worth ₹ 34 Crores in paper companies shown in the balance sheet of M/s. Dotex Merchandise Pvt Ltd, were sold on paper to the paper companies of Shr .....

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..... ultimate addition was only in respect of the share subscription amount of ₹ 30.20 crores received during the year. The Ld. AR therefore submitted that the reason for which the assessment was reopened was completely divorced from the findings ultimately recorded by the AO. He submitted that mere reference in the recorded reasons about the historical facts of raising of equity capital by the appellant company from time to time did not in any manner justify the Ld. DR s argument that the AO had formed reason to believe that subscription to the equity capital received during the relevant year represented income escaping assessment. The Ld. AR pointed out that in the reasons recorded the AO was consciously aware that the share capital raised during the relevant year was only ₹ 30.20 crores which was separate and distinct from the investments which the assessee had made in shares of other bodies corporate at a cost of ₹ 34 crs and which were liquidated subsequent to assesse s take over by RPG Group. Having taken note of these two distinct facts, the AO had consciously formed his reason to believe that proceeds received from sale of investment shares of paper companies, .....

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..... aped assessment; he had categorically recorded as follows: Thus there is reason to believe that the income of the assessee company amounting to ₹ 34 crores has escaped assessment for the assessment year 2010-11. Proceeding u/s 147 is initiated, issue notice u/s 148 for the assessment year 2010-11. 9. The Ld. AR therefore submitted that if the notice u/s 148 and the reasons recorded on the same date are read in conjunction and harmoniously then the only conclusion that can be drawn is that the AO having recorded his own satisfaction about alleged escapement of income straightaway initiated the proceedings u/s 147 by issuing the notice u/s 148 without obtaining prior approval u/s 151 of the Act. The Ld. AR also brought to our attention the last paragraph of the notice u/s 148 which required the AO to inform assessee whether prior approval of the appropriate authority was obtained or not. In the notice issued to the assessee, copy of which is filed before us, the AO specifically cancelled out this part. He therefore submitted that it was apparent that without complying with the mandatory requirement of Section 151, the AO issued the notice u/s 148 of the Act on 09/02/2015 itself .....

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..... ement of income. Without doing so, the jurisdictional fact necessary to usurp jurisdiction to reopen the regular assessment cannot be made by the AO. For the said proposition, the Ld. AR drew our attention to following case laws : - PCIT Vs. Meenakshi Overseas Ltd., 395 ITR 677(Del.) - PCIT Vs. Tupperware India Pvt. Ltd., 236 Taxman 494 (Del) - PCIT Vs. Shodiman Investments (P) Ltd., 93 taxmann.com 153 (Bom) - CIT VsParamjitKaur, 168 Taxman 39 (P&H HC) - Pr.CITVs RMG Polyvinyl (I) Ltd, 83 taxmann.com 348 (Del HC) - CIT VsInsceticides (India) Ltd, 357 ITR 330 (Del HC) - CIT Vs SFIL Stock Broking Ltd., 325 ITR 285 (Del HC) 11. We have heard rival submissions and gone through the facts and circumstances of the case. From the foregoing facts and applicable legal provisions the short question which needs to be adjudicated in the present appeal is whether the assessment order u/s 147 passed by the AO was legally sustainable when no addition was made by the AO with reference to reasons which were recorded prior to issue of notice u/s 148 of the Act. From the reasons recorded by the AO on 09.02.2015, we find that in the first instance the AO set out historical background of the equity .....

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..... d reasons the AO recorded his satisfaction about income escaping assessment to the extent of ₹ 34 crores and not ₹ 30.20 crores being the amount received during the relevant year on issue of fresh shares. We therefore have no hesitation in holding that the reason for which the AO recorded his satisfaction about income escaping assessment had no connection whatsoever with the fresh issuance of equity shares totaling ₹ 30.20 crores. In our considered opinion the AO s satisfaction was specific and it was with reference to alleged introduction of unaccounted cash totaling ₹ 34 crores in the guise of sale of investments by Mr. Mahawar. We however find that neither any enquiry with regard to this issue was conducted by the AO prior to completion of assessment nor we find any discussion with regard to the said issue in the AO s order. We also note that in the order passed u/s 147, no addition was ultimately made in respect of the issue for which the satisfaction was recorded by the AO. In the foregoing factual background therefore the question arises for our consideration is whether the order u/s 147 was legally sustainable in view of the catena of judgments cited .....

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..... , the AO had specifically recorded his satisfaction as follows: …As expected after the purchase by Sanjeev RPG group, the investment worth ₹ 34 Crores in paper companies shown in the balance sheet of M/s. Dotex Merchandise Pvt Ltd, were sold on paper to the paper companies of Shri Mahawar and sale proceeds was credited in the bank account of Dotex Merchandise Pvt Ltd. As is clear from the statement of Shri Mahawar that the source of the sale proceed is cash provided by Sanjeev RPG Group to Shri Mahawar, who has routed it through different layers of paper companies and cheques have finally gone from paper companies of Shri Mahawar to Dotex Merchandise Pvt Ltd. Thus there is reason to believe that the income of the assessee company amounting to ₹ 34 crores has escaped assessment for the assessment year 2010-11. Proceedings u/s 147 is initiated, issue notice u/s 148 for the assessment year 2010-11. 13. From the above it is apparent that in AO s opinion the introduction of alleged cash received from RPG Group in the guise of sale proceeds of investments totaling ₹ 34 crores constituted the income escaping assessment for AY 2011-12 and for which the proceedings .....

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..... hough the law grants him co-terminus and plenary powers to the extent of issues and sources considered by the AO. 15. In this regard we rely on the judgment of the Hon ble Delhi High Court in the case of CIT Vs Software Consultants (supra). In this case, in the course of search conducted against the promoter, the AO had found fixed deposits with bank and the person searched explained that the assessee company had provided the requisite funds. Based on such statement, the assessment of the assessee company was reopened u/s 147. While examining assessee s sources of funds, the AO noted that the assessee had issued capital during the year and enquiry in respect of fresh issue was conducted u/s 133(6) of the Act. Ultimately the assessment was completed without making any addition. Later the CIT exercising powers u/s 263 held the assessment to be erroneous because in his opinion further enquiry was necessary in respect of fresh issue of shares, which the AO had failed to make. On appeal the Tribunal quashed the order of the CIT against which the appeal u/s 260A was preferred. While deciding the appeal, the Hon ble High Court held as follows: 9. One of the contentions, which has been acc .....

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..... of any issue which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under the section." 11. Thereafter, the High Court referred to the decision of the Rajasthan High Court in the case of CIT v.Shri Ram Singh, [2008] 306 ITR 343 in which it has been observed as under: "It is only when, in proceedings under section 147 the Assessing Officer, assesses or reassesses any income chargeable to tax which has escaped assessment for any assessment year, with respect to which he had 'reason to believe' to be so, then only, in addition, he can also put to tax, the other income, chargeable to tax, which has escaped assessment, and which has come to his notice subsequently, in the course of proceedings under section 147. To clarify it further, or to put it in other words, in our opinion, if in the course of proceedings under section 147, the Assessing Officer were to come to the conclusion, that any income chargeable to tax, which, according to his 'reason to believe', had escaped assessment for any assessment year, did not escape assessment, then, the mere fact that the Assessing Officer entertained a reason to believe, .....

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..... ich he intends to take into account, he would be required to issue a fresh notice under section 148. 19. In the present case, as is noted above, the Assessing Officer was satisfied with the justifications given by the assessee regarding the items, viz., club fees, gifts and presents and provision for leave encashment, but, however, during the assessment proceedings, he found the deduction under sections 80HH and 80-I as claimed by the assessee to be not admissible. He consequently while not making additions on those items of club fees, gifts and presents, etc., proceeded to make deductions under sections 80HH and 80-I and accordingly reduced the claim on these accounts. 20. The very basis of initiation of proceedings for which reasons to believe were recorded were income escaping assessment in respect of items of club fees, gifts and presents, etc., but the same having not been done, the Assessing Officer proceeded to reduce the claim of deduction under sections 80HH and 80-I which as per our discussion was not permissible. Had the Assessing Officer proceeded to make disallowance in respect of the items of club fees, gifts and presents, etc., then in view of our discussion as above .....

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..... note the mandate of the section, which provides that : 'If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under this section...'. A bare perusal of the above provision divulges that the AO, in the course of assessment pursuant to notice u/s. 148, can make two types of additions, viz., first, the addition for which he formed reason to believe about the income chargeable to tax escaped assessment (hereinafter also called the 'foundational addition') and second, any other addition which comes to his notice subsequently in the course of the proceedings under this section (hereinafter also called the 'other addition'). It is trite that the 'other addition' can stand only if the 'foundational addition' is made by the AO. The logic appears to be simple and plain. Reassessment can't be made at the drop of a hat. There must be valid rea .....

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..... to a next level, no different consequences will emerge, if the 'foundational addition' is itself finally deleted in an appeal. In such a scenario, the 'other addition' made by the Assessing Officer would automatically cease to stand in isolation. This view has been affirmed by the Hon'ble jurisdictional High Court in CIT v. AdhunikNiryatIspat Ltd. [2011] 63 DTR 212 (Delhi). In that case, the return filed by the assessee for the asst. yr. 1999-2000 declaring income @ ₹ 1,22,460 was processed under s. 143(1) of the IT Act. However, notice was issued under section 148 of the Act subsequently, on the information received from the Director of IT (Inv.), New Delhi, to the effect that the assessee had accepted the accommodation entries from M/s. I.G. Properties (P.) Ltd., M/s. Parivartan Capital & Financial Services (P.) Ltd. and from M/s. Victoria (P.) Ltd. in the garb of share capital. The AO passed the reassessment order making additions of ₹ 31 lakh on account of unexplained share capital including the capital subscribed by the aforesaid three applicants on the basis of which the assessment was reopened. However, during the assessment proceedings, .....

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..... fter recording reasons for reopening the assessment. Further, he may also assess or reassess such other income which has escaped assessment and which comes to his notice subsequently in the course of proceedings under this section. Some Courts have held that the Assessing Officer has to restrict the reassessment proceedings only to issues in respect of which the reasons have been recorded for reopening the assessment. He is not empowered to touch upon any other issue for which no reasons have been recorded. The above interpretation is contrary to the legislative intent. With a view to further clarifying the legislative intent, it is proposed to insert an explanation in section 147 to provide that the Assessing Officer may assess or reassess income in respect of any issue which comes to his notice subsequently in the course of proceedings under this section, notwithstanding that the reason for such issue has not been included in the reasons recorded under sub-section (2) of section 148. This amendment will take effect retrospectively from 1st April, 1989 and will, accordingly, apply in relation to assessment year 1989-1990 and subsequent years. [Clause 57]' 10. It is palpable th .....

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..... ssue for which the reason was recorded, the AO is not permitted to make addition in respect of any other issue for which reason was not recorded prior to issue of the notice. The reason for arriving at such conclusion is not far to seek. It is a cardinal principle of any fiscal statute that any proceeding under the fiscal law must attain finality and it cannot be allowed to remain open forever. In the income-tax proceedings also there must be a finality and the assessee must be made known that his assessment has attained finality once the proceedings are completed by the AO by passing an order of assessment u/s 143(3) or 144 or 147, as the case may be. Once the assessment is complete, it is no more open for the tax authority to re-enter the issue of determination of income or to review or revise the assessment already completed. In the circumstances unless there are compelling reasons, the tax authority is not permitted to reopen the completed assessment and accordingly adequate safeguards are incorporated by the legislature in the statute. Even though provisions of Section 147, 154 or 263 permit the tax authorities to re-compute and re-assess the income of the assessee, yet the Ac .....

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..... . However in a case where the assessee demonstrates that the key used by the AO for reopening of assessment is either incorrect or where reason recoded is abandoned in the course of reassessment proceedings, then as a corollary it has to be held that the key used by the AO for opening the lock was inappropriate or incorrect and thereby the lock placed earlier on the concluded assessment remained unopened and therefore the AO could not enter upon the arena of reassessment. In a case where the reason recorded prior to issue of notice u/s 148 is not at all pursued or acted upon by the AO in the course of reassessment, then it is no more open for the AO to pursue some other issues for which no reasons were recorded prior to issuance of notice u/s 148 of the Act. This legal proposition is well explained by the Hon ble Delhi High Court in the case of CIT Vs Ranbaxy Laboratories Limited (supra) the ratio of which was followed in the above two decisions referred earlier.In this judgment the Hon ble Delhi High Court had held as follows: "18. We are in complete agreement with the reasoning of the Division Bench of the Bombay High Court in the case of CIT v. Jet Airways (I) Limited [2011 .....

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..... reasons to believe were recorded were income escaping assessment in respect of items of club fees, gifts and presents, etc., but the same having not been done, the Assessing Officer proceeded to reduce the claim of deduction under sections 80HH and 80-I which as per our discussion was not permissible. Had the Assessing Officer proceeded to make disallowance in respect of the items of club fees, gifts and presents, etc., then in view of our discussion as above, he would have been justified as per Explanation 3 to reduce the claim of deduction under sections 80HH and 80-I as well. 21. In view of our above discussions, the Tribunal was right in holding that the Assessing Officer had the jurisdiction to reassess issues other than the issues in respect of which proceedings are initiated but he was not so justified when the reasons for the initiation of those proceedings ceased to survive. Consequently, we answer the first part of question in affirmative in favour of Revenue and the second part of the question against the Revenue." 18. We find that the ratio laid down by the Hon ble Delhi High Court in the foregoing judgment, was applied by the coordinate Bench of this Tribunal in t .....

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..... ncluding some other issues. Therefore, no substantial question of law arises. Hence, the application and the appeal are dismissed. 20. We also rely on the judgment of the Hon ble Rajasthan High Court in the case of CIT Vs Ram Singh (supra) wherein it was held as follows: 24. Reverting back to language of section 147, this much is clear, that the sine qua non for conferment of jurisdiction on the AO, to initiate proceedings under that section is, that he should have "reason to believe" that "any income chargeable to tax has escaped assessment for any assessment year" and that, being that situation, being available, i.e., the AO having entertained a "reason to believe", obviously on valid grounds, he acquires the jurisdiction to assess or reassess "such income", which obviously means, the income, which was chargeable to tax, and had escaped assessment for any assessment year, according to his "reason to believe", and while so assessing or reassessing, he can also, in addition, assess or reassess "any other income chargeable to tax which has escaped assessment and which may come to his notice subsequently in the course of proceedi .....

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..... t of interpretation of the word "and" as "or", the existence of the word "also" is of a great significance, being of conjunctive nature, and leaves no manner of doubt in our opinion, that it is only when, in proceedings under section 147 the AO, assesses or reassesses any income chargeable to tax, which has escaped assessment for any assessment year, with respect to which he had "reason to believe" to be so, then only, in addition, he can also put to tax, the other income, chargeable to tax, which has escaped assessment. and which has come to his notice subsequently, in the course of proceedings under section 147. 29. To clarify it further, or to put it in other words, in our opinion, if in the course of proceedings under section 147, the AO were to come to conclusion, that any income chargeable to tax, Which, according to his "reason to believe", had escaped assessment for any assessment year, did not escape assessment, then, the mere fact, that the AO entertained a reason to believe, albeit even a genuine reason to believe, would not continue to vest him with the jurisdiction, to subject to tax, any other income, chargeable to tax .....

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..... tinct transactions; one involving the shares which the assessee issued to twenty two share subscribing companies and another involving sale of investments which the assessee held in other bodies corporate. It may be so that Shri Mahavar or companies managed by him were connected with both the set of transactions. However both the sets of transactions were separate from each other and consequences flowing from these sets of transactions were also separate and could not be intermixed. In the reasons the AO recorded his satisfaction about escapement of income specifically with reference to assessee s transactions involving sale of investments totaling ₹ 34 Crs. The satisfaction recorded did not any manner suggest that in AO s opinion share subscription amount of ₹ 30.20 Crs. received during the year from 22 subscribers represented assessee s income escaping assessment. We therefore concur with the findings of the Ld. CIT(A) that no addition was made in the order u/s 147/143(3) dated 31.03.2016 with reference to the reasons for which the assessment was reopened and in that view of the matter the impugned order u/s 147/143(3) is held to be legally unsustainable. Hence, we do .....

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