Income Tax Appellate Tribunal – Mumbai
City & Industrial Development … vs Ito, Ward-15(1)(3), Mumbai on 15 November, 2021 IN THE INCOME TAX APPELLATE TRIBUNAL
MUMBAI BENCH “C” MUMBAI
BEFORE SHRI SAKTIJIT DEY (JUDICIAL MEMBER) AND
SHRI S. RIFAUR RAHMAN (ACCOUNTANT MEMBER)
ITA No. 795/MUM/2021
Assessment Year: 2016-17
City and Industrial Development Income Tax Officer, Ward-15(1)(3),
Corporation of Maharashtra Limited, Vs. Ground floor, Aayakar Bhavan,
“Nirmal” 2nd floor, Nariman Point, Maharshi Karve Road,
Mumbai-400 021. Mumbai-400 020.
PAN No. AACCC 3303 K
Appellant Respondent
Assessee by : Mr. Madhur Aggarwal, AR
Revenue by : Ms. Shreekala Pardeshi, DR
Date of Hearing : 18/08/2021
Date of pronouncement : 15/11/2021
ORDER
PER S. RIFAUR RAHMAN, A.M.
The present appeal is filed by the assessee against the order of the Pr.
Commissioner of Income Tax -6, Mumbai [in short ‘Pr. CIT’] for the
assessment year 2016-17 dated 31.03.2021 and passed order u/s 263 of the
Income Tax Act, 1961 (in short the Act).
2. Brief facts of the case are, the assessee has filed the return of income
for assessment year 2016-17 on 20.03.2018 declaring total income of
Rs.5,00,000/-. The case was selected for complete scrutiny under CASS.
Subsequently, the assessment was completed u/s 143(3) of the Income Tax
Act, 1961 (in short ‘Act’) on 29.12.2018 accepting the return of income at
Rs.5,00,000/-
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3. On perusal of the records, Pr. CIT-6, Mumbai observed that AO erred
in accepting the return of income filed for assessment year 2016-17. He
observed that the assessee claimed huge exemption under the garb of
Article 289(1) of the Constitution of India by considering itself as an agent
of the Government of Maharashtra. He observed that the assessee-company
was claiming exemption u/s 10(20A) of the Act till assessment year 2002-
03. With the deletion/amendment of the said section w.e.f. A.Y. 2003-04, no
exemption remained available to the assessee company. It is only after
withdrawal of exemption u/s 10(20A) of the Act and for A.Y 2003-04
onwards the assessee company has come out with a novel claim that
receipts earned by it in business activities belonged to the Government of
Maharashtra and it was only acting as an agent of the state government. In
support of such claim the assessee relied upon Article 289(1) of the
constitution of India and claimed that since it was an agent of the Govt. of
Maharashtra, the excess of receipts over expenditure was not income liable
to tax in its hand. From facts of case as mentioned above it is clear that the
contention of the assessee being an agent is just an after-thought and a ruse
to escape the tax liability under the provisions of the Income-tax Act, 1961
by the assessee w.e.f. A.Y. 2003-04 and onwards.
3.1 During 263 proceedings, the assessee brought to the notice of the Pr.
CIT that in earlier years i.e. assessment year 2014-15 and 2015-16 the
Department has cancelled the assessment order passed by the respective
AO by invoking provision u/s 263 of the Act. It is also specifically brought
to the notice of Pr. CIT that the orders passed u/s 263 in those assessment
years were set aside by the ITAT. Even after the above information was
brought to the notice of the present Pr. CIT, the Pr. CIT observed in his
order at page 17 that the Department has filed appeal before Hon’ble High
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ITA No. 795/M/2021
Court and the matter is still pending. Still he preferred to cancel the order
passed u/s 143(3) for this assessment year with the following observation :
“15. I have carefully considered the submissions of the assessee but I am of
the view that the assessee is not an agent of the Government and,
therefore, the tasks performed by the assessee cannot be equated with the
tasks performed by the State Government. Further, Article 289(2) of the
Constitution of India enables levy of Union Taxation on State Government
owned companies and, therefore, any income accruing to the assessee must
be subjected to the provisions of the Income Tax Act, 1961. The assessee is
a company and there is not dispute that the company is a person as per the
provisions of section 2(31) of the Income Tax Act, 1961. As per the
provisions of section 4, the total income of the previous year of every
person is chargeable to income tax. As per the provisions of section 5, the
total income of any previous year of a person who is resident will include
all income from whatever sources derived which is received or deemed to
be received in India, accrues or arises or deemed to accrue or arise in India
or accrues or arises to him outside India during the previous year. Taken
these sections into consideration together, it can be said that any income of
a person who is resident in India received, accrues or arises in India, or
outside India during the previous year is taxable as per the provisions of
the Income Tax Act, 1961. The assessee was incorporated as a Company on
19.03.1970 with a share capital which was wholly and exclusively
subscribed by the Government of Maharashtra with the object of creation
of New Town of Navi Mumbai, New Aurangabad, New Nasik etc. Therefore,
the assessee is a company which is incorporated as a Company on
17.03.1970 with the entire share capital subscribed by the Government of
Maharashtra. But this fact itself does not prove that the tasks performed
by this company are the tasks of the State Government. Even if the
company is fully owned by the State Government, it cannot be held that it is
performing the tasks of the Government. Development of new towns during
the contemporary India is not the exclusive task of the Government. It is
the task which is also being performed by the private sector with equal
efficiency and competence. As per provisions of the Competition Act, 2002,
no favourable treatment could be given even if the company is owned by
the Government. It is against the provisions of the Competition Act, 2002.
Once the company is incorporated by the Government, it will have to
compete with other players in the sector and the playground should be
even and for this it is necessary that all the conditions including taxability
of income should be same without any discrimination with the companies
owned by the Government or in private sector.
15.1 Development of the township cannot be considered as the task of
the State Government. It is not reserved for the State Government alone.
There are various models for development of townships in India. Some
companies are State owned, yet some others are owned by the non-
Government entities and yet others are joint ventures of the Government
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ITA No. 795/M/2021
and the private sectors which is in common parlance known as Private
Public Partnerships (PPP). The various case laws which have been cited by
the assessee or by the Hon’ble Tribunal in its order are not considered as
supporting the view that the assessee company is the surrogate of the State
Government and, therefore, tax cannot
16 With due respect to the Tribunal and other Courts, as the decision
are not considered applicable in the case of the assessee, appeal has been
filed by the Department against the order of Hon’ble IT AT in A. Y. 2006-07
and 2007-08 before the Hon’ble Bombay High Court.
17. It is also considered necessary to clarify here that wherever the
order of the Assessing Officer or the Hon”ble Tribunal are against the stand
taken by the Department in A.Y. 2006-07, remedial action if available is
being taken in consonance to the stand of the Department in A.Y. 2006-07
which is that the income of the assessee after omission of section 10(20A)
is taxable w.e.f. A.Y 2003-04. If in any such order, remedial action cannot
be taken, then it is due to technical reasons that action cannot be taken but
it does not represent the acceptance of such orders which are deviating
from the stand taken by the Department in AY. 2006-07.
18 Other replies of the assessee in respect of certain components of
income mentioned in show cause notice u/s 263 which are not considered
relevant to take the decision as to whether the order passed by the
Assessing Officer is erroneous in so far as it is prejudicial to the interest of
revenue. In case the order passed by the Assessing Officer u/s.143(3) on is
considered as erroneous, in so far as it is prejudicial to the interest of
revenue, in response to the notice u/ s. 263 dated 12.12.2018, then, suitable
directions will be given in respect of these aspects also.
19. At last on page 11, the assessee has cited the judgements of Hon’ble
Supreme Court of India in the case of Malabar Industrial Company Ltd. V/s
Commissioner of Income Tax 243 ITR 81 and CIT vs Max India Ltd. 295
I’TR 282. The judgements of the Hon’ble Supreme Court are taken into
consideration and with full respect to the judgements, it is submitted that
in the case of the assessee only one view is possible and that is the acts of
the assessee company are not the acts of the State and, therefore, the
income of the assessee company like any other company must be subject to
the provisions of the Income Tax Act 1961 and Income Tax Rules 1962.
20. The assessee company is stated to be appointed as a New Town
Development Authority for developing the Navi Mumbai Area ujs.113(3A)
of the Maharashtra Regional and Town Planning Act of 1966 (i.e .MRTP
Act) and as Special Planning Authority for other notified areas u/
s.40(1)(b) read with section 113(3A) of MRTP Act for carrying out its
activities as New Town Development Authority and Special Planning
Authority as per the provision of section 113(3A) and 40(1)b)
r.w.s.113(3A) and various Government Resolutions (GRs) and Notification
issued by the Government of Maharashtra. In assessment order for AY.
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ITA No. 795/M/2021
2007-08, it was mentioned that the Government Resolution dated
24.01.1972 and 11.01.1974 were passed appointing the assessee company
as the New Town Development Authority for Navi Mumbai. However, the
said Government Resolutions nowhere speak of appointing the assessee
company as an agent of the Government of Maharashtra. In the instant
case, the assessee company was claiming exemption u/s. 10(20A) of the Act
till A.Y. 2002-03. With the deletion/ omission of the said section, no
exemption remained available to the assessee company. Returns of income
have been filed by the assessee company for A.Y. 2003-04 to 2006-07 either
u/s.139 or in response to notice/ s.148 of the I.T.Act. It is only after
withdrawal of exemption u/s. 10(20A) of the Act and further after
declaring income in its own hands in its return filed for A.Y.2003-04 to
A.Y2005-06, that assessee company has come out with a novel claim that
its income belonged to the Government of Maharashtra and the assessee
company was acting merely as an agent of the State Government. Thus it is
clear that the contention of being an agent is just an after-thought and a
ruse to escape the tax liability as per the provisions of the Income Tax Act,
1961. The assessee company has gone ahead with a claim of TDS credit in
the return filed for A.Y. 2016-17. This further confirms that the
corresponding income belongs to the Assessee Company itself and is,
therefore, taxable in its hands only. The assessee company was in appeal
for the similar disallowance in earlier assessment years. Thus matter was
subjudice.
21. The Apex Court in the case of APSRTC reported in (1964) 052 ITR
0524 (SC) holds that assessee is not an arm of the Government and,
therefore, its income cannot be considered as the income of the
Government and thus denied the claim of the assessee. In DCIT, Circle 1(1)
Vs Andhra Pradesh Beverages (ITA No.360 & 41 7 /Hyd/ 2015 in
December, 2016 held that privilege fee payable by the petitioner to the
State Government would be taxable. Section 40(b) of the Income Tax Act
has been amended to provide that any amount paid by way of fee, charges
etc. shall not be allowed as deduction to such undertaking under the head
profits and gains of the business.
22. The assessee company is taking a stand that it is an Agent of the
Government and that the remuneration of Rs.5,00,000/-is the only taxable
income in its hands. This proposition is totally wrong as there is no
exemption available under the Income Tax Act for the assessee to claim
any sort of exemption of the income out of its operations. In fact, the
assessee was duty bound to cast the balance sheet and profit and loss
account so as to reflect the exact and true account of the incomes arising
out of such invitees being performed by the assessee. The assessee has not
adhered to the accounting standards and instead chose to show the entire
income accrued as transferred to the State. The taxability of such an
income in the hands of the assessee before apportionment to the State
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ITA No. 795/M/2021
Government is the precise issue which is the subject matter of the revision
under 263.
23. Therefore, I consider the order passed by the Assessing Officer u/
s.143(3) on 29-12.2018 as erroneous and in so far as it is prejudicial to the
interest of revenue and, therefore, the order passed by the Assessing Officer
is set aside with à direction to pass the order denovo after giving an
opportunity of being heard before passing an order in determining the
total income of the assessee under various heads of income. The Assessing
Officer will not hold the task performed by the assessee as actions of the
Government and, therefore, the provisions of Article 289(1) of the
Constitution of India will not be applicable in this case.”
4. At the time of hearing, the above facts on record were brought to our
notice by Ld. AR and he brought to our notice that the detailed findings of
the ITAT in assessment year 2014-15 and 2015-16 and submitted that the
issue involved in all the three assessment years are exactly similar and
there is no change in the business of the assessee during this assessment
year. He submitted that ITAT has relied on various judicial decisions of
various Courts and came to the conclusion. He prayed that similar facts are
involved and technically the issue is covered in favour of the assessee.
5. On the other hand, the Ld. DR stated that the order of assessment is
set aside by the Pr. CIT in order to keep the issue alive and he relied on the
orders passed by the Pr. CIT.
6. Considered the rival submissions and material on record. We
observed that exactly similar issues came up before the Co-ordinate Bench
in the assessment year 2014-15 wherein (AM) is the party to it and by
considering various case laws decided by the Hon’ble Jurisdictional High
Court on the subject of whether the assessee is an agent of the State of
Maharashtra or not, the issue was decided in favour of the assessee by the
Co-ordinate Bench. For the sake of brevity it is reproduced below :
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ITA No. 795/M/2021
“23. Considering the rival submission and material placed on record as well as
order passed by Pr. CIT u/s 263 of the Act, we observe that assessee is a
statutory body and incorporated on 17.19.70 with the entire share capital
subscribed by the Govt. of Maharashtra and Govt. of Maharashtra appointed
the assessee as new town developer and spl. planning authority for the
development of Mumbai City. In the resolution passed by the Govt. of
Maharashtra, assessee was appointed in exercise of powers conferred u/s
113(3A) MRTP Act 1966 as an agent and to function on behalf of Govt. of
Maharashtra. The Hon’ble High Court of Bombay in the case of Percival Joseph
Pareira, both single bench as well as divisional bench has held that the assessee
is an agent of Govt. of Maharashtra as per section 113(3A) of the MRTP Act.
The question arose whether the assessee should be treated as agent by relying
on the decision of the Hon’ble High Court of Mumbai in the several cases. Pr. CIT
has rejected the contention of the assessee by relying on the several appeal filed
before Hon’ble Bombay High Court as there is no decision from the Hon’ble
High Court in the Income Tax Act. He acknowledged the Coordinate Bench of
ITAT has held that the assesse is an agent of Govt. of Maharashtra in the AY
2006-07 and Pr. CIT has expressed his view not to follow the decision of the
order of Jurisdictional ITAT. From the facts brought out by the Ld. Sr. Counsel
that in the previous assessment years commencing from AY 2003-04 to 2013-14
except AY 2006-07 and 2007-08, in all the AYs, the revenue has accepted that
assessee is an agent of the Govt. of Maharashtra and completed the
assessments, that means in all AYs commencing from AY 2003-04 except AY
2006-07 and AY 2007-08 , the department has accepted the assessee is an
agent and whatever income offered by the asessee as agent was accepted by the
department. The addition in the previous AY 2013-14, the assessment was
completed u/s 143(3) by accepting the assessee as agent and income offered by
the assessee as income from the business.
24. From the order passed by Pr. CIT u/s 263, we noticed that he intends to
correct the assessments made by the AO u/s 143(3) by observing that the case
of the assessee fall under Article 289(1) and presumed that assessee is claiming
the exemption under Article 289(1), whereas all these years, assessee has filed
the return of income and declared income earned from the Govt. of
Maharashtra as an agent. As per the resolution passed by the Govt. of
Maharashtra, the remuneration fixed at Rs. 5 lakhs per annum and the same
was declared by the assessee over the years and the department has accepted
the stand taken by the assessee from AY 2003-04 to 2013-14 other than AY
2006-07 and 2007- 08 in which department is in appeal before High Court.
When the AO accepted the assessee is an agent and completed the assessment
u/s 143(3) over the years, it means that the AO completed the assessment with
one particular view, whereas Pr. CIT intends to correct the above view and
presumed that the case of assessee falls under Article 289(1) and come to a
conclusion that assessee is not comes under Article 289 and subjected to tax
under Income Tax Act, therefore, in our view, this is another view in the case of
assessee. Therefore, Pr. CIT cannot invoke the provision of section 263 of the Act
when two views are possible as held in the case of CIT vrs. Max India Ltd,
wherein it was held as under:-
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ITA No. 795/M/2021
1. In our view at the relevant time two views were possible on the word
“profits” in the proviso to Section 80HHC(3). It is true that vide the 2005
amendment the law has been clarified with retrospective effect by
insertion of the word “loss” in the new proviso. We express no opinion on
the scope of the said amendment of 2005. Suffice it to state that in this
particular case when the order of the Commissioner was passed under
Section 263 of the Income Tax Act, 1961, two views on the said word
“profits” existed. In our view the matter is squarely covered by the
judgment of this Court in the case of Malabar Industrial Co. Ltd. v. CIT
reported in (2000) 243 ITR 83; as also by the judgment of the Calcutta
High Court in the case of Russell Properties P. Ltd. v. A. Chowdhury, Addl.
CIT.
2. At this stage we may clarify that under paragraph 10 of the judgment
in the case of Malabar Industrial Co. Ltd. v. CIT (2000) 243 ITR 83 this
Court has taken the view that the phrase “prejudicial to the interests of
the revenue ” under Section 263 has to be read in conjunction with the
expression “erroneous” order passed by the assessing officer. Every loss
of revenue as a consequence of an order of the assessing officer cannot
be treated as prejudicial to the interests of the revenue. For example,
when an Income Tax Officer adopted one of the courses permissible in
law and it has resulted in loss of revenue ; or where two views are
possible and the Income Tax Officer has taken one view with which the
Commissioner does not agree, it cannot be treated as an erroneous
order prejudicial to the interests of the revenue , unless the view taken
by the Income Tax Officer is unsustainable in law…….
25. Respectfully, following the above decision, in our considered view that Pr.
CIT has adopted one possible view in the present case and the order passed by
Pr. CIT u/s 263 of the Act is accordingly dismissed as assessment order may be
prejudicial but not erroneous. Further, the main dispute arouse due to whether
assessee is an agent or not. In the civil appeal, Hon’ble high court held that
assessee is an agent as per Section 113(3A) of MRTP Act. PCIT refused to
consider this decision as it is not adjudicated under Income Tax Act. We cannot
neglect the Hon’ble high court findings, we have to accept the definition/
meanings by higher court and most of the time, meanings and definitions are
adopted from other law or from wisdoms of higher courts in Income Tax
proceedings. PCIT has taken a strange stand not to follow the Judicial
precedents in order to defend his proceedings u/s 263. Accordingly order u/s
263 is set aside.”
7. From the above decision of the Co-ordinate Bench it is clear that the
issue raised by the Revenue are considered by the Bench and decided the
issue in favour of the assessee. Even then, the Revenue set aside the order
passed u/s 143(3) in subsequent assessment year i.e. 2015-16 and again in
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ITA No. 795/M/2021
impugned assessment year also Ld. Pr. CIT by invoking the provision of
section 263 of the Act set aside the assessment order. It clearly shows and
demonstrate that the respected officers do not want to respect the judicial
precedents. It is apt to bring to the notice respective of the officers the
decision of the Hon’ble Supreme Court in the case of UoI and Ors v.
Kamlakshi Finance Corporation Ltd. Special Leave Petition (Civil) No. 7717
of 1990 wherein, it is held as under :
“6. Sri Reddy is perhaps right in saying that the officers were not actuated by
any mala fides in passing the impugned orders. They perhaps genuinely felt
that the claim of the assessee was not tenable and that, if it was accepted, the
Revenue would suffer. But what Sri Reddy overlooks is that we are not
concerned here with the correctness or otherwise of their conclusion or of any
factual malafides but with the fact that the officers, in reaching in their
conclusion,by-passed two appellate orders in regard to the same issue which
were placed before them,one of the Collector (Appeals) and the other of the
Tribunal. The High Court has, in our view,rightly criticised this conduct of the
Assistant Collectors and the harassment to the assessee caused by the failure of
these officers to give effect to the orders of authorities higher to them in the
appellate heirarchy. It cannot be too vehemently emphasised that it is of utmost
importance that, in disposing of the quasi-judicial issues before them, revenue
officers are bound by the decisions of the appellate authorities; The order of the
Appellate Collector is binding on the Assistant Collectors working within his
jurisdiction and the order of the Tribunal is binding upon the Assistant
Collectors and the Appellate Collectors who function under the jurisdiction of
the Tribunal. The principles of judicial discipline require that the orders of the
higher appellate authorities should be followed unreservedly by the
subordinate authorities. The mere fact that the order of the appellate authority
is not “acceptable” to the department – in itself an objectionable phrase – and is
the subject matter of an appeal can furnish no ground for not following it
unless its operation has been suspended by a competent court. If this healthy
rule is not followed, the result will only be undue harassment to assessees and
chaos in administration of tax laws.
7. The impression or anxiety of the Assistant Collector that, if he accepted the
assessee’s contention, the department would lose revenue and would also have
no remedy to have the matter rectified is also incorrect. Section 35-E confers
adequate powers on the department in this regard. Under Sub-section (1),
where the Central Board of Direct Taxes come across any order passed by the
Collector of Central Excise with the legality or propriety of which it is not
satisfied, it can direct the Collector to apply to the Appellate Tribunal for the
determination of such points arising out of the decision or order as may be
specified by the Board in its order.Under Sub-section(2) the Collector of Central
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ITA No. 795/M/2021
Excise, when he comes across any order passed by an authority subordinate to
him, if not satisfied with this legality or propriety, may direct such authority to
apply to the Collector (Appeals) for the determination of such points arising out
of the decision or order as may be specified by the Collector of Central Excise in
his order and there is a further right of appeal to the department. The position
now, therefore, is that,if any order passed by an Assistant Collector or Collector
is adverse to the interests of the Revenue, the immediately higher
administrative authority has the power to have the matter satisfactorily
resolved by taking up the issue to the Appellate Collector or the Appellate
Tribunal as the case may be. In the light of these amended provisions, there can
be no justification for any Assistant Collector or Collector refusing to follow the
order of the Appellate Collector or the Appellate Tribunal, as the case may be,
even where he may have some reservations on its correctness. He has to follow
the order of the higher appellate authority. This may instantly cause some
prejudice to the Revenue but the remedy is also in the hands of the same officer.
He has only to bring the matter to the notice of the Board or the Collector so as
to enable appropriate proceedings being taken under Section.35-E (1) or (2) to
keep the interests of the department alive. If the officer’s view is the correct one,
it will no doubt be finally upheld and the Revenue will get the duty, though
after some delay which such procedure would entail.
8. We have dealt with this aspect at some length, because it has been suggested
by the learned Additional Solicitor General that the observations made by the
High Court, have been harsh on the officers. It is clear that the observations of
the High Court, seemingly vehement, and apparently unpalatable to the
Revenue, are only intended to curb a tendency in revenue matters which, if
allowed to become widespread, could result in considerable harassment to the
assesses-public without any benefit to the Revenue. We would like to say that
the department should take these observations in the proper spirit. The
observations of the High Court should be kept in mind in future and the utmost
regard should be paid by the adjudicating authorities and the appellate
authorities to the requirements of judicial discipline and the need for giving
effect to the orders of the higher appellate authorities which are binding on
them.”
8. From the above, it is clear that Hon’ble Supreme Court urged the
Department to take these observations in the proper spirit and it supported
the stand taken by the High Court on the judicial discipline. It directed that
appellant as well adjudicating authorities to follow the judicial discipline.
Therefore, in the given case, the tax authorities are not intending to follow
the order passed by the Co-ordinate Bench, not just one year but subsequent
year also with the intention to keep the issue alive. They failed to
differentiate that when they file the appeal before Hon’ble High Court, the
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ITA No. 795/M/2021
issue is automatically alive. It is not necessary to invoke the same provisions
every year. Particularly, when the Co-ordinate Bench decided the issue
relying on the Hon’ble Jurisdictional High Court decision, still they are not
satisfied and raking up the same issue every year without giving proper
respect to judicial discipline.
9. Therefore, we direct the tax authorities to follow the due process of
law and take appropriate steps while dealing with the settled issues before
them keeping in mind the judicial discipline. Since, the issue involved in this
appeal filed by the assessee are already settled in favour of the assessee.
Accordingly, we set aside the order passed u/s 263 and in the result, the
grounds raised by the assessee are allowed.
10. In the result, the appeal filed by the assessee is allowed.
Order pronounced in the open Court on 15/11/2021.
Sd/- Sd/-
(SAKTIJIT DEY) (S. RIFAUR RAHMAN)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Mumbai;
Dated: 15/11/2021
Rahul Sharma, Sr. P.S.
Copy of the Order forwarded to :
1. The Appellant
2. The Respondent.
3. The CIT(A)-
4. CIT
5. DR, ITAT, Mumbai
6. Guard file.
BY ORDER,
//True Copy//
(Dy./Assistant Registrar)
ITAT, Mumbai
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