Tuesday, 25 June 2013

Doctrine of promissory estoppel not applicable to legislature – Withdrawal of tax exemption is not unconstitutional


The Karnataka High Court (“High Court”) has rendered a significant ruling in the case of MindTree Limited and Others (“Petitioners”) wherein important principles on judicial review by constitutional courts and the applicability of Doctrine of Promissory Estoppel to legislature and statutes have been articulated. The High Court confirmed the validity of the legislative amendments made to withdraw tax exemptions in this ruling which was pronounced in respect of a writ petition filed by various stakeholders of Special Economic Zones (“SEZ”) against the abrupt withdrawal of exemption from Minimum Alternate Tax[1] (“MAT”) and Dividend Distribution Tax[2] (“DDT”) on their profits.



We have summarized the key aspects of the decision in relation to the above issue.


Reason for filing the writ petition


Upon enactment of the Special Economic Zones Act, 2005 (“SEZ Act”) corresponding provisions were introduced in the Income-tax Act, 1961 (”IT Act”) to provide complete tax exemption on the profits earned by units located in SEZs and developers of SEZs by way of newly introduced tax holiday sections (section 10AA and section 80-IAB respectively) and specifically excluding SEZ units and developers of SEZ from the purview of MAT under section 115JB of the IT Act. Profit distributions by SEZ developers were also specially exempted from the purview of DDT under section 115-O of the IT Act.


However, by insertion of proviso to section 115JB(6) and 115-O(6) vide Finance Act 2011, the exemptions from MAT and DDT were withdrawn respectively. Stakeholders of SEZ comprising of units, developers and co-developers had committed huge capital outlays for setting up SEZ infrastructure with the belief that there would be no tax costs, at least in the near term. Aggrieved by the abrupt withdrawal of the exemptions, the Petitioners (being SEZ developers/co developers /units) filed a writ petition to challenge the constitutional validity of such amendment by relying on the Doctrine of Promissory Estoppel and Doctrine of Legitimate Expectation.


Petitioner’s contentions


· The Petitioners, by acting on the provisions of the SEZ Act and exemptions provided under various Acts including the IT Act, committed huge investments in establishing SEZs / SEZ units. The investments which were made by borrowing substantial loans from banks and financial institutions were with the belief and expectation that their profits would not be subject to income-tax. The abrupt and arbitrary withdrawal of the MAT and DDT was a breach of an express promise made by the legislature and such amendment is opposed to the Doctrine of Promissory Estoppel.


· Amendments were introduced abruptly and to the detriment of petitioners and as such the same opposed to Doctrine of Legitimate Expectation. A sunset clause must be a road map to end any tax exemption instead of arbitrarily ending the same;


· The impugned amendments are opposed to the very object of SEZ Act are unconstitutional and beyond the power and authority and administrative competence of Ministry of Finance since matters relating to development, operation and maintenance of SEZs were to be dealt by Ministry of Commerce. Further, it was contended that the amendment to the IT Act proposed by the Finance Minister also resulted in the amendment of Schedule –II of the SEZ Act (Schedule – II which is a part of the SEZ Act contains the modifications to the provisions of IT Act which would apply to SEZ developers and SEZ units) which was illegal and without authority of law.


Contentions of the Respondent


· The exemptions provided under section 115JB and 115-O of the IT Act did not contain any sunset provisions and as such the impugned amendments are in accordance with law.


· It was contended that withdrawal of benefit under the fiscal policy was a legislative action and hence not hit by the Doctrine of Promissory Estoppel.


· It was also argued that the respondent that exemptions granted to petitioners eroded the tax base and accordingly the disputed amendments were introduced in public interest and hence they are valid.


Decision of the High Court


The High Court dealt with the matter in question by first examining the scope of judicial review entrusted with the courts by virtue of Article 226 of the Constitution of India (“Constitution”). The High Court stated that such power is to be exercised very rarely and in exceptional circumstances only. Further, the High Court deliberated upon the validity of the amendments in light of Article 14 of the Constitution[3] and upheld the validity of the amendments.


The significant aspects of the High Court’s judgment are captured in the following paragraphs:


· On the scope of judicial review, relying on the various decisions of the Apex court, the High Court held that the Courts can invalidate the law made by the legislature only when the legislature lacks competency to do so or when the law enacted is violative of any constitutional provisions. In exercising the powers of judicial review, the courts do not and cannot go into the question of wisdom behind legislative measure. Further, it would be unwise for the Court to interfere into a domain of economic or social spheres since they are essentially experimental and complicated situations;


· On the legislative competency aspect, the High Court held that the Rules of Loksabha do not bar the Finance Minister from moving a bill for an amendment to the SEZ Act though it comes under the domain of the Ministry of Commerce. Further, placing reliance on the decision of the Apex court in the case of Madurai District Central Co-operative Bank Ltd Vs Third ITO4 , the High Court further held that the finance Minister by introducing the Finance Act before the parliament has legislative competence to amend IT act or any other matter relating to the tax in any other statute.


· In respect of abrupt withdrawal being unfair, the High Court stated that as a settled principle, there are no permanent tax exemptions or fiscal incentives in law and accordingly, the withdrawal of such exemption was required to cover the lapse in the current law. It also stated that setting a road map for the tax incentives is not a condition precedent for the Parliament to introduce a sunset clause. Also, the parliament has sovereign legislative power to withdraw tax exemption by way of legislative amendment and does not have to introduce a sunset clause.


· Examining Article 14 of the Constitution dealing with principles of equity, the High Court observed that while all other Companies were subject to MAT and DDT, SEZ establishments were exempted and as such this lead to a discrimination in treatment of the companies. Accordingly, the amendments were in line with Article 14 and not against it.


· Further, the High Court stated that the Doctrine of Promissory Estoppel and Legitimate Expectation were concepts evolved by courts to avoid injustice to a party. The High Court held that seeking relief under Doctrine of Promissory Estoppel was a superior relief than Doctrine of Legitimate Expectation and thus only the former was being discussed. In this regard, relying on the Supreme Courts’ rulings in Motilal Pasampat Sugar Mills Co Ltd Vs State of Uttar Pradesh and Union of India vs Godfrey Philips India Ltd it in which it was held that there can be no promissory estoppel against the legislature in the exercise of its legislative functions nor can the Government or any public authority be debarred by promissory estoppel from enforcing a statutory prohibition. The High Court concluded that courts would decline to enforce this Doctrine if it results in great hardship to the government and would be prejudicial to public interest.


· Further, the High Court negated the arguments on the applicability of the Doctrine of Promissory Estoppel by stating that the amendments were in fact yielding to equity in the instant case on account of the following:


- The lack of the sunset clause was a flaw in the law and the same has been removed;

- Inequality between SEZ participants and other assesses has been removed;

- Exemptions were eroding the tax and the same have now been removed;

- Fiscal policy of the state and any decision in the economic sphere is within the Government’s prerogative; and

- The amendments have not transgressed the Petitioner’s fundamental rights which have been guaranteed by the Constitution


 

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