Income Tax Appellate Tribunal – Hyderabad
Deputy Commissioner Of Income … vs Biological E Limited, Hyderabad on 25 October, 2021 IN THE INCOME TAX APPELLATE TRIBUNAL
HYDERABAD BENCHES “B”: HYDERABAD
(THROUGH VIRTUAL CONFERENCE)
BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER
AND
SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER
ITA No. 1879/H/2017
Assessment Year: 2010-11
Biological E Ltd., Hyderabad. Vs. Dy. Commissioner of
Income-tax,
PAN – AAACB7873P Circle – 1(3), Hyderabad.
(Appellant) (Respondent)
ITA No. 2070/H/2017
Assessment Year: 2010-11
Dy. Commissioner of Vs. Biological E Ltd.,
Income-tax, Circle – 1(3), Hyderabad.
Hyderabad.
PAN – AAACB7873P
(Appellant) (Respondent)
Assessee by: Shri V. Siva Kumar
Revenue by: Shri Rohit Mujumdar
Date of hearing: 05/10/2021
Date of pronouncement: 25/10/2021
ORDER
PER L.P. SAHU, A.M.:
Both these appeals are cross appeals filed by the
assessee as well as revenue directed against CIT(A) – 8,
Hyderabad’s order dated 19/09/2017 for AY 2010 -11
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involving proceedings u/s 143(3) of the Income Tax Act,
1961 ; in short “the Act.
2. Briefly, the facts of the case are that the assessee
engaged in the manufacturing and sale of formulations an
bulk drugs, filed its return of income admitting total loss of
Rs. 4,71,210/-, which was revised to the loss of Rs.
5,89,41,575/- in the revised return filed on 31/03/2013
under the normal provisions and income of Rs.
17,00,61,779/- under the provisions of section 115JB. The
said returns were processed u/s 143(1) of the Act.
Subsequently, the case was converted to scrutiny through
CASS and accordingly, statutory notices were issued to the
assessee, against which, the AR of the assessee furnished
the required information.
2.1 The AO completed the assessment u/s 143(3) of the
Act on 28/03/2013 revising the total loss of Rs.
2,06,23,441/- as against the loss declared by the assessee
at Rs. 5,89,41,575/-, by making following disallowances:
1. Disallowance of excess claim of weighted
deduction u/s 35(2AB) – Rs. 1,40,14,670
2. Disallowance of long term capital loss
– Rs. 24,76,342
3. Disallowance u/s 14A – Rs. 12,83,188
4. Disallowance of bad debts – Rs. 1,87,97,676
5. Disallowance of wealth tax expense – Rs. 1,98,328
6. On account of sale of depreciable assets –
Rs. 15,47,930
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3. When the assessee preferred an appeal before the
CIT(A), the CIT(A) partly allowed the appeal of the
assessee.
4. Against the order of CIT(A), both the assessee and
revenue are in appeal before the ITAT.
5. First we take up the case of the assessee. Assessee has
raised 4 grounds of appeal, out of which Ground Nos. 1 & 4
are general in nature, hence, need no adjudication. Ground
No. 2 is against the action of CIT(A) in sustaining the
disallowance of long term capital loss of Rs. 24,76,342/ -.
Ground No. 3 is against the action of CIT(A) in sustaining
the disallowance of Rs. 77524/- u/s 14A rwr 8D(2)(iii) of
the Act.
6. As regards the disallowance of long term capital loss
of Rs. 24,76,342/-, from the computation of income, the AO
observed that the assessee had claimed long term capital
loss of Rs. 24,76,342/- and set off of it against the income
from business as per the details furnished by the assessee.
Further, he observed that the land was located at Agra and
the same was acquired in the year 1962. The AO asked the
assessee to produce sale deed in respect of the said
property and in response, the AR of the assessee
furnished special power of attorney dated 10/08/2010
wherein it was mentioned that advance of Rs. 1.50 crores
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was received by the assessee company from the pro spective
buyer one Shri Bhagwandass and possession of the land
was given through SPA. The AO, therefore, observed that
the land transfer did not take place in AY 2010 -11 and no
evidence was filed by an authority stating that the land was
really transferred to the prospective buyer even after the
date of the assessment. He, therefore, held that the assessee
was not eligible to claim long term capital loss in AY
2010-11 and accordingly disallowed assessee’s claim of
LTCL of Rs. 24,76,342/-.
6.1 The CIT(A) confirmed the disallowance made by the
AO by holding that no sale deed has been produced either
before the AO or before the undersigned that transfer of the
property had indeed taken placed in the year under
consideration.
6.2 Before us, the ld. AR of the assessee submitted that
since the property was handed over and full consideration
was received by the assessee company the impugned
property shall be considered to have been transferred in
accordance with the provisions of section 2(47) of the Act.
In this connection, he relied on the decision of the Hon’ble
High Court of Bombay in the case of Dr. Joao Souza Proenca
Vs. ITO, 90 Taxmann.com 63 to submit that since the
assessee received entire consideration and also handed
over possession, transfer u/s 2(47) should be considered to
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have taken place. He submitted that in his deed/affidavit
dated 31/03/2010, Shri Bhagwandas has unequivocally
affirmed that he got possession of the impugned property
from the assessee company and was in possession of the
property from 29/03/2010 and also that entire sale
consideration of Rs. 1.50 crores was also paid to the
assessee company.
6.3 The ld. DR, on the other hand, besides relying on
the orders of revenue authorities submitted that no sale
deed has been produced by the assessee before the
authorities that the transfer of the property had indeed
taken place in the year under consideration from any
authorities i.e. SRO. The assessee has not satisfied the
conditions as per the definition of “transfer” as
contemplated in section 2(47) of the Income Tax Act. 1961.
6.4 We have considered the rival submissions and
perused the material on record as well as gone through the
orders of revenue authorities. Even before us, the assessee
failed to submit the sale deed, if any, issued by the
authority to establish that the property had been
transferred in the year under consideration. Mere
considerations received and possession handed over
without any documentary evidence for enjoyment of the
property to the buyer is not sufficient, hence, the section
2(47)(vi) is also not applicable. As per the documents
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available, we find that the transaction was done in the
financial year 2009-10 and till the date of hearing, the
assessee is unable to rebut the finding of the assessing
officer in regard to non-submission of the sale deed. The
hon’ble Supreme Court of India in the case of CIT Vs. Balbir
Singh Maini [2017] 86 taxmann.com 94 (SC) has settled the
issue in respect of the transfer of the property where
the registered sale deed has not been executed in favour of
the prospective buyer. The relevant paras are as under:
“18. Section 53A, as is well known, was inserted by the Transfer
of Property Amendment Act, 1929 to import into India the
equitable doctrine of part performance. This Court has in
Shrimant Shamrao Suryavanshiv. Pralhad Bhairoba Suryavanshi
[2002] 3 SCC 676 stated as follows:
“16. But there are certain conditions which are required to be
fulfilled if a transferee wants to defend or protect his
possession under Section 53-A of the Act. The necessary
conditions are:
(1) there must be a contract to transfer for
consideration of any immovable property;
(2) the contract must be in writing, signed by the
transferor, or by someone on his behalf;
(3) the writing must be in such words from which the
terms necessary to construe the transfer can be
ascertained;
(4) the transferee must in part-performance of the contract
take possession of the property, or of any part thereof;
(5) the transferee must have done some act in furtherance of
the contract; and
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(6) the transferee must have performed or be willing to
perform his part of the contract.”
19. It is also well-settled by this Court that the protection
provided under Section 53A is only a shield, and can only be
resorted to as a right of defence. Rambhau Namdeo Gajre v.
Narayan Bapuji Dhgotra [2004] 8 SCC 614 , para 10. An
agreement of sale which fulfilled the ingredients of Section 53A
was not required to be executed through a registered instrument.
This position was changed by the Registration and Other Related
Laws (Amendment) Act, 2001. Amendments were made
simultaneously in Section 53A of the Transfer of Property Act and
Sections 17 and 49 of the Indian Registration Act. By the
aforesaid amendment, the words “the contract, though required
to be registered, has not been registered, or” in Section 53A of the
1882 Act have been omitted. Simultaneously, Sections 17 and 49
of the 1908 Act have been amended, clarifying that unless the
document containing the contract to transfer for consideration
any immovable property (for the purpose of Section 53A of 1882
Act) is registered, it shall not have any effect in law, other than
being received as evidence of a contract in a suit for specific
performance or as evidence of any collateral transaction not
required to be effected by a registered instrument. Section
17(1A) and Section 49 of the Registration Act, 1908 Act, as
amended, read thus:
“17(1A). The documents containing contracts to transfer for
consideration, any immovable property for the purpose of
Section 53A of the Transfer of Property Act, 1882 (4 of 1882)
shall be registered if they have been executed on or after the
commencement of the Registration and Other Related Laws
(Amendment) Act, 2001 and if such documents are not
registered on or after such commencement, then they shall
have no effect for the purposes of the said Section 53A.”
“49. Effect of non-registration of documents required to be
registered. No document required by Section 17 or by any
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provision of the Transfer of Property Act, 1882 (4 of 1882), to
be registered shall–
(a) affect any immovable property comprised therein, or
(b) confer any power to adopt, or
(c) be received as evidence of any transaction affecting such
property or conferring such power, unless it has been
registered:
Provided that an unregistered document affecting
immovable property and required by this Act or the Transfer
of Property Act, 1882 (4 of 1882), to be registered may be
received as evidence of a contract in a suit for specific
performance under Chapter II of the Specific Relief Act, 1887
(1 of 1877) or as evidence of any collateral transaction not
required to be effected by registered instrument.”
20. The effect of the aforesaid amendment is that, on and after
the commencement of the Amendment Act of 2001, if an
agreement, like the JDA in the present case, is not registered, then
it shall have no effect in law for the purposes of Section 53A. In
short, there is no agreement in the eyes of law which can be
enforced under Section 53A of the Transfer of Property Act. This
being the case, we are of the view that the High Court was right
in stating that in order to qualify as a “transfer” of a capital asset
under Section 2(47)(v) of the Act, there must be a “contract”
which can be enforced in law under Section 53A of the Transfer
of Property Act. A reading of Section 17(1A) and Section 49 of the
Registration Act shows that in the eyes of law, there is no
contract which can be taken cognizance of, for the purpose
specified in Section 53A. The ITAT was not correct in referring to
the expression “of the nature referred to in Section 53A” in
Section 2(47)(v) in order to arrive at the opposite conclusion.
This expression was used by the legislature ever since sub-section
(v) was inserted by the Finance Act of 1987 w.e.f. 01.04.1988. All
that is meant by this expression is to refer to the ingredients of
applicability of Section 53A to the contracts mentioned therein. It
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is only where the contract contains all the six features mentioned
in Shrimant Shamrao Suryavanshi (supra), that the Section
applies, and this is what is meant by the expression “of the nature
referred to in Section 53A”. This expression cannot be stretched
to refer to an amendment that was made years later in 2001, so
as to then say that though registration of a contract is required
by the Amendment Act of 2001, yet the aforesaid expression “of
the nature referred to in Section 53A” would somehow refer only
to the nature of contract mentioned in Section 53A, which would
then in turn not require registration. As has been stated above,
there is no contract in the eye of law in force under Section 53A
after 2001 unless the said contract is registered. This being the
case, and it being clear that the said JDA was never registered,
since the JDA has no efficacy in the eye of law, obviously no
“transfer” can be said to have taken place under the aforesaid
document. Since we are deciding this case on this legal ground, it
is unnecessary for us to go into the other questions decided by the
High Court, namely, whether under the JDA possession was or
was not taken; whether only a licence was granted to develop the
property; and whether the developers were or were not ready
and willing to carry out their part of the bargain. Since we are of
the view that sub-clause (v) of Section 2(47) of the Act is not
attracted on the facts of this case, we need not go into any other
factual question.”
6.5 Therefore, we uphold the order of the CIT(A) in
confirming the AO’s action in disallowing the assessee’s
claim of long term capital loss of Rs. 24,76,342/ -.
Accordingly, the ground raised by the assessee on this issue
is dismissed. However, it is clear from the order of AO that
the assessee can offer income under the head “long term
capital gain” in the year in which the land is duly
transferred in all respects as per the above cited decision
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to the proposed buyer to which the assessing officer can
decide the issue as per law in the respective year.
7. As regards ground No. 3 relating to the disallowance
of Rs. 77,523/- u/s 14A rwr 8D(2)(iii) of the Act, the AO
noted that the assessee had shown dividend income of Rs.
3,46,312/- on the investments made of Rs. 3,10,09,726/-,
whereas Rs. 23,22,22,889/- was claimed towards interest
and financial charges. Since no disallowance of expenditure
incurred for earning tax free income was made, the AO
invoked the provisions of section 14A rwr 8D(2) and
disallowed Rs. 12,05,664/- under rule 8D(2)(ii) and Rs.
77,524/- under rule 8D(2)(iii) totaling to Rs. 12,83,188/-.
7.1 Before the CIT(A), the AR of the assessee submitted
that no investments were made during the year and all
investments made into equity shares and mutual funds
in the earlier years. The AR further submitted that the
assessee’s paid-up capital is Rs. 4.05 Cr. and has reserves of
Rs. 74.01 crores as on 31/03/2010, thus having total own
funds of Rs. 78.96 crores. Since, no fresh investments were
made in the year under consideration and the investments
made in the previous years was out of the income earned in
those years and further as the company has sufficient own
funds, the AR submitted that disallowance u/s 8D(2) is not
justified.
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7.2 After considering the submissions of the assessee,
the CIT(A) deleted the disallowance made by the AO under
rule 8D(2) (ii) on the ground that assessee has huge own
funds when compared to a small investments made in
equity shares and mutual funds.
7.3 The CIT(A) confirmed the disallowance under rule
8D(2)(iii) on the ground that since the said rule provides
for nominal disallowance of expenditure as per the given
working towards establishment/administration expenses at
0.5% average value of investment as appearing in the
balance sheet on the first day and last of the pre vious year
as the disallowance.
7.4 Before us, the ld. AR of the assessee in his
written submissions, inter-alia, stated that no particular
expenses was brought to its notice which could have been
incurred for the purpose of earning exempt income, that
there were no such expenses of managerial nature which
could be attributed towards earning of exempt income and
that during the year no activity of sale or purchase was
done in respect of shares. He relied on the decisions in
the case of Priya Exhibitors (P) Ltd. Vs. ACIT, 27
Taxmann.com (Delhi Trib.) and the judgment of Bombay
High Court in the case of GodreJ & boyce Mfg. Co. Ltd. Vs.
DCIT 194 Taxman 203.
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7.5 The ld. DR, on the other hand relied on the orders
of revenue authorities.
7.6 We have considered the rival submissions and
perused the material on record as well as gone through the
orders of revenue authorities. We do not accept the
contention of the assessee that no administrative/
managerial expenses incurred by the assessee for earning
exempt income. Assessee earned dividend income of Rs.
3,46,312/- which is exempt u/s 10(34)/10(35) of the Act.
The investment relevant to earning of exempt income is as
under:S.No. Investment As at As at Increase Dividend
31-03-2009 31-03-2010 during earned
the year
1. Corporation 9,76,000 9,76,000 Nil 97,600
Bank
2 Bank of 7,61,300 7,61,300 Nil 29,790
Baroda
3 LIC Liquid 34,56,782 36,75,704 2,18,922 2,18,922
Fund –
Dividend
plan
Total dividend 3,46,312
7.7 The findings given by the CIT(A) are not in
accordance with rule 8D(2)(iii). The disallowance can be
made under this rule only on 0.5% of the average value of
investments which yield exempt income. The assessee has
received dividend from the investments as quoted in the
above table and the average value of these investments is
Rs 53,03,543/- and 0.5% of the average value comes to
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Rs. 26,518/-. Therefore, the disallowance is to be restricted
to Rs. 26,518/- and assessee gets relied of Rs. 51006/-,
hence, this ground of assessee is partly allowed.
8. In the result, appeal of the assessee is partly allowed
in above terms.
9. As regards revenue’s appeal, the revenue has raised 4
grounds of appeal, out of which ground Nos. 1 & 4 are
general in nature, hence, need no adjudication. Ground No.
2 is against the action of the CIT(A) in allowing assessee’s
claim of bad debits of Rs. 90,01,443/- and ground No. 4 is
against deletion of addition of Rs. 97,96,233/-.
10. As regards ground No. 3 relating to the addition of
Rs. 90,01, 443/-, the AO observed that the assessee claimed
bad debts of Rs. 1,49,86,880/- regarding receivables from
C&F agents. The AO noted that the assessee could not
furnish any details regarding efforts taken through legal
measures and also did not furnish any confirmations
regarding write off of the receivables from those C&F
agents/dealers. The assessee requested for allowing debts
lying for more than 3 years before FY 2009-10 as bad debts
written off. Considering the assessee’s reques t, only a sum
of Rs. 59,85,437/- was allowed by the AO as bad debts on
the ground that the age of such debts is more than 3 years
before FY 2009-10 and the balance amount of Rs.
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90,01,443/- being relatively younger debts, was disallowed.
10.1 Before the CIT(A), the AR of the assessee submitted
that taking of legal steps for recovery of receivables and
confirmations for write off of receivables is not necessary
for allowing write off bad debts after the amendments made
to section 36(1)(viii) w.e.f. 01/04/1989. He relied on the
decision of the Hon’ble Supreme Court in the case of TRF
Vs. CIT, 323 ITR 397 wherein it was held that bad debts
written off are allowable as deduction and establishing that
such debts have become bad is not required. The AR also
relied upon the Circular No. 12/2016, dated 30/05/2016 in
this regard.
10.2 The CIT(A) after considering the submissions of the
assessee, observed that it is now well settled law that it is
not necessary for the assessee to establish that the debt had
in fact become bad to be written off as bad debt in view of
the amendment made to section 36(1)(vii) from
01/04/1989 and the decision of Hon’ble Supreme Court in
the case of TRF (supra). He, therefore, held that the action
of the AO in allowing debts of more than three years only as
bad debts is erroneous and, thus, directed the AO to allow
the entire bad debts written off as allowable.
10.3 The ld. DR relied on the order of AO while the ld.
AR reiterated the submissions made before the CIT(A) and
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case law cited before him.
10.4 We have considered the rival submissions and
perused the material on record as well as gone through the
orders of revenue authorities. On going through the
financial statements, in the P&L account bad
debts/advances/deposits written off o f Rs. 4,28,33,731/-,
which includes 90,01,443/-, which is the disputed amount.
The ld. CIT (A) has rightly allowed this issue after relying
on the judgement cited supra. In view of the above
observations, we do not find any infirmity in the decision
of CIT(A) in directing the AO to allow the claim of bad
debts of Rs. 90,01,443/- and upholding the order of CIT(A)
on this count, we dismiss the ground No. 02 raised by the
revenue on this issue.
11. As regards ground No. 3 relating to the addition of Rs.
97,96,233/-, the AO observed that the assessee has written
off the deposits/advances amounting to Rs. 97,96,233/ -,
which represent advances given to various suppliers and
deposits placed with various parties. The AO held that since
these deposits/advances have never been part of income in
earlier years write off of these advances/deposits is not
allowable as expenditure because the same are not revenue
items. He, therefore, disallowed the deposits/advances
written off of Rs. 97,96,233/-.
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11.1 Before the CIT(A), the AR of the assessee submitted
that the assessee is engaged in the business of supply of
medical formulations to various Government Departments
and in the process, bid for tenders and pays EMD while
bidding for tenders. It also made deposits with various
Government Departments for taking facilities from them in
the course of carrying on its business. Apart from the
above, the appellant pays advances to various part ies for
supply of materials and for providing services. After
adjustments by the said parties, some balances are left over
in the said account for a number of years which cannot be
recovered and they were written off, which is allowable as
deduction u/s.28 and 37(1) of the Act. The AR relied upon a
number of decisions particularly that of Mohan Meakin Vs
CIT (348 ITR l09)(Del), wherein it was held that the
deposits/advances made during the course of business
which later become unrealizable for various reaso ns are
allowable as deduction. The AR also relied upon the recent
judgment of Hon’ble ITAT, Visakhapatnam in the case of
DCIT vs Friends Shoes Company to buttress the argument.
11.2 The CIT(A) deleted the disallowance by observing
as under:
“6.2 I have carefully considered the issue and the
submissions made by the AR. The AO disallowed the
deposits/advances written off on the ground that they
have never been part of income in the earlier years and
therefore can’t be allowed as bad debts u/s.36(1)(vii) of
the Act. The question here is not write off bad debts but
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the deposits/ advances given to government
departments and the suppliers in the course of business,
a small part of which could not be recovered from them
for a number of years. This is evident from the details of
such deposits/advances written off as filed by the AR.
This issue has been subject matter of Hon’ble ITAT,
Visakhapatnam in the case 0; DOT vs Friends Shoes
Company wherein it was held that the write off of
advances/deposits are allowable as deduction u/s.37 of
the Act. Since the facts of the appellant are similar to
the above mentioned case law, the disallowance made
by the AO is deleted and the grounds of appeal is
allowed.”
11.3 The ld. DR relied on the order of AO while the ld.
AR besides relying on the order of CIT(A) reiterated the
submissions made before him.
11.4 We have considered the rival submissions and
perused the material on record as well as gone through the
orders of revenue authorities. We observe that the CIT(A) is
not justified in deleting the disallowance of Rs. 97,96,233/ –
made by the AO on account of deposits/advances written
off by the assessee, because these advances/deposits
relate to various parties and no correspondence between
the assessee and the parties has taken place. On going
through the pages 23 & 24 of paper book, in which, list of
deposits/advances written off during the year 2009 -10 in a
tabular form furnished by the assessee, there are variou s
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types of advances given to different persons, suppliers,
employees, EMD for participating in tenders in the Govt.
departments, etc. To claim bad debts, the amounts must be
treated as income but, the issue in dispute relates to
advance/deposits which have never been considered as
income of the assessee. Even if it is considered as
expenditure u/s 37(1) of the Act, the expenditure must be
crystalized during the impugned AY, but, the assessee failed
to produce any documentary evidence to substantiate its
claim that the parties to whom advances have been given as
per pages 23 & 24 of the paper book that the parties were
refused to pay back the advances. In support of our
decision, we rely on the coordinate bench of ITAT, Mumbai
benches in the case of Elite International (P.) Ltd. v. Assistant
Commissioner of Income-tax, Circle-6(2), Mumbai, [2017] 83
taxmann.com 213 (Mumbai – Trib.). The case law relied on by
the assessee cited supra as well as relied on by the ld.
CIT(A) are not applicable to the case of the a ssessee. In
view of the above observations, we set aside the order of
the CIT(A) and restore that of the AO on this issue. Thus,
the ground No. 03 of the revenue is allowed.
12. In the result, appeal of the revenue is partly allowed
in above terms.
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13. To sum up, appeal of the assessee and the appeal of
the revenue are partly allowed.
Pronounced in the open court on 25 th October, 2021.
Sd/- Sd/-
(S.S. GODARA) (L. P. SAHU)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Hyderabad, Dated: 25 th October, 2021.
kv
Copy to :
1 Biological E Ltd., 18/1 & 3, Azamabad,
Hyderabad – 500 020
2 DCIT, Circle – 1(3), Hyderabad.
3 CIT(A) – 8, Hyderabad
4 Pr. CIT – 1, Hyderabad
5 ITAT, DR, Hyderabad.
6 Guard File.
Comments