Friday, 21 March 2014

Whether provisions of Sec 56(2)(vii) apply to all capital assets, including bonus and rights shares offered on proportionate basis even if offer price is less than fair market value - NO: ITAT

THE issues before the Bench are - Whether the provisions of section 56(2)(vii) apply to all capital assets, including bonus and rights shares offered on proportionate basis even if the offer price is less than the fair market value; Whether in case the value of the property in the additional shares is derived from that of the existing shareholding, it can be presumed that additional property have been received by the shareholder; Whether in case there is no disproportionate allotment, shares are allotted pro-rata to the shareholders, based on their existing holdings, there is any scope for any property being received by them on the said allotment of shares; Whether in case the value of additional shares is derived from that of the existing shares, the decline in the
value thereof can be excluded from valuation; Whether purchase or transfer implies existence of a property, while the shares, where out of un-appropriated capital, come into existence only on their allotment and Whether the consequences can alter the meaning of a statutory provision, even where such meaning is plain and unambiguous. And the verdict partly goes in favour of the assessee.
Facts of the case
The assessee is an HUF, holding 15,000 shares in a company by the name Dorf Ketal Chemicals Pvt. Ltd. (DKCPL). The entire share capital was held by the family members of the assessee’s karta’s family, representing 4.98% of the share capital (3,01,316 shares), was offered 3,13,624 additional shares at the face value rate of Rs.100/- each, on a proportionate basis. It subscribed to and was accordingly allotted 1,94,000 of those shares, on 28.01.2010, i.e., along with the other shareholders, who were allotted - on the same terms, not only the shares similarly offered to them but also that not subscribed to by the other shareholders, as 1,19,624 (313624 – 194000) shares by the assessee. The shares were received by the assessee on 10.02.2010. As the book value of the shares of DKCPL as on 31.03.2009 was Rs.1,538/- per share, which was to be adopted as a measure of their FMV under the applicable rules, AO treating the difference of Rs.1,438/- per share as the extent of the inadequate consideration, in terms of section 56(2)(vii)(c) added toward the acquisition of additional shares. On appeal, CIT(A) confirmed AO's order.
The first issue was regarding the provisions applicable to a transaction as the one under reference. Assessee was contending it to be only an issue of right shares. It was contended that in case issue of right shares was being considered as a instrument of capital budgeting, it would equally applicable to bonus shares. As per the decision of SC in the case of K.P. Varghese vs. ITO (2002-TIOL-128-SC-IT), SC took into account all the relevant factors, including the purpose for which the relevant provision of section 52 was brought on the statute, as clarified by the official pronouncements preceding it or in this regard, invoking the rule of contemporanea expositio as well as the principles of construction.
It was argued that the word ‘property’ occurring in section 56(2)(vii) was defined to mean capital assets as specified therein. Though the same lists ‘shares and securities’, one of the objections raised by the assessee was that the shares come into existence only on their allotment. However, the right to acquire the shares at a concessional rate comes into effect on the passing of the necessary resolution by the Board of Directors (BOD) of the issuer-company. It was agreed that the shareholders get the right to acquire the additional shares on the passing of the board resolution, but the receipt of the property was only on their allotment, on which date the shares, a specified property, was in existence. In the cases of Shree Gopal and Company vs. Calcutta Stock Exchange Ltd. and Khoday Distilleries Ltd. vs. CIT (2008-TIOL-213-SC-IT), it had been explained that allotment was generally neither more nor less than the acceptance by the company of the offer to take shares. All it means was appropriation out of the previously un-appropriated capital of a company of a certain number of shares to a particular person. Till such allotment the shares do not exist as such, and in a sense come into existence on their allotment. In this view of the matter, the plea of the rights under reference being not a property specified under the provision or the provision being sought to be applied by the Revenue to a non-existing property, was without basis. In fact, before Tribunal even the date of receipt - which itself implies that the property exists, i.e., whether on allotment (28.01.2010) or the receipt of shares (10.02.2010), was a bone of contention. This was rendered inconsequential inasmuch as both the dates fall during the relevant previous year; and being separated by a small time lag, even the valuation would not alter to any material extent, and which becomes a relevant consideration inasmuch as the valuation date was the date of the receipt of the property. Though, the shares were received on their allotment. What stands received by the assessee subsequently on 10.02.2010 were the share certificates, i.e., the document evidencing its title thereto. The two were different, and the shares as well as the property therein vest in the assessee on the allotment of the shares, whereat the same stand constructively received; the payment of which had also been made by that date. The provision of section 56(2)(vii) does not apply to bonus shares, as in that case there is no receipt of any property by the shareholder, and what stands received by him is the split shares out of his own holding. There was, accordingly, no question of any gift of or accretion to property; the share-holder getting only the value of his existing shares, which stands reduced to the same extent.
Held that,
++ we may though, at the outset, clarify that the instant issue cannot be called a rights issue. Section 81 of the Companies Act, 1956 is not applicable to a private company (s.81(3)), so that it is firstly not obliged to issue shares to the existing shareholders only, and again, even so, on a proportionate basis. That apart, we state so as the scheme does not have a provision for the renunciation of rights by the existing shareholders. The same could thus at the option of the issuing company be offered for allotment to any other, i.e., whether existing shareholder or not. Thus, though the issue has elements of a right issue inasmuch as the offer is made in the first instance to the existing shareholders on the basis of their shareholding on proportional basis, the same cannot be strictly termed as one; the company appropriating that right, which could be offered to another. A rights issue, as informed by the AR, stands not defined either under the Companies Act or under the Securities Contracts (Regulation) Act, 1956. The company has, accordingly, correctly termed the issue, not satisfying all its parameters, as akin to a rights issue, before the CIT(A), which the AR was before us at pains to dislodge. Nothing, however, turns on the same, as would apparent from the foregoing discussion, and as we shall presently see in more detail. We say so as to the extent the value of the property in the additional shares is derived from that of the existing shareholding, on the basis of which the same are allotted, no additional property can be said to have been received by the shareholder. The Revenue argues otherwise, contending that the fall in the value of the existing holding, if any, is not to be taken into account or reckoning. The argument is equally misconceived, i.e., as that by the assessee qua the applicability of the provision to bonus shares. It fails to take into account the nature of the transaction. To exemplify, shares in the ratio (say) 1:1 are offered for subscription at the face value of Rs.100/- as against the current book value of Rs.1,500/- (say). The moment a right share is allotted, the book value shall fall to Rs.800/- per share. It is easy to see that the new share partakes a part of the value of the existing share, which is only on the basis of the underlying assets on the company’s books. The excess (over face value), or Rs.1,400/-, gets apportioned over two shares as against one earlier, which is already the shareholders’ property. This is also the basis and the premise of the decisions in the case of Dhun Dadabhoy Kapadia vs. CIT [1967] 63 ITR 651 (SC) and H. Holck Larsen vs. CIT [1972] 85 ITR 285 (Bom), relied upon and referred to by the parties before us. As long as, therefore, there is no disproportionate allotment, i.e., shares are allotted pro-rata to the shareholders, based on their existing holdings, there is no scope for any property being received by them on the said allotment of shares; there being only an apportionment of the value of their existing holding over a larger number of shares. There is, accordingly, no question of section 56(2)(vii)(c), though per se applicable to the transaction, i.e., of this genre, getting attracted in such a case. A higher than proportionate or a non-uniform allotment though would, and on the same premise, attract the rigor of the provision. This is only understandable inasmuch as the same would only be to the extent of the disproportionate allotment and, further, by suitably factoring in the decline in the value of the existing holding. In the context of the example cited, by taking the difference at Rs.700/- per share for such shares. We emphasize equally on a uniform allotment as well. This is as a disproportionate allotment could also result on a proportionate offer, where on a selective basis, i.e., with some shareholders abstaining from exercising their rights (wholly or in part) and, accordingly, transfer of value/property. We observe no absurdity or unintended consequences as flowing from the per se application of the provision of s. 56(2)(vii)(c) to right shares, which by factoring in the value of the existing holding operates equitably. It would be noted that the section, as construed, would apply uniformly for all capital assets, i.e., drawing no exception for any particular class or category of the specified assets, as the ‘right’ shares. No addition u/s. 56(2)(vii)(c) would thus arise in the undisputed facts of the instant case, and the assessee succeeds;
++ the foregoing arguments and premises would also meet and state the basis for our not accepting the Revenue’s argument toward no cognizance being taken of the existing shareholding – on the strength of which only the additional shares are allotted to the assessee or the decline in their value consequent to the issue of additional shares in-asmuch as the same are not the subject matter of receipt, i.e., to which the provision pertains and is restricted to. It stood further contended before us that the ratio of the decision in the case of Dhun Dadabhoy Kapadia would be no longer applicable, i.e., even in principle, so that the said decline would be of no consequence in view of the specific provisions being since incorporated u/s 55, providing for the cost of shares under such situations, as for example a nil cost for bonus shares. The capital asset received by the assessee, it may be appreciated, are to be valued as on the date of its receipt. That is, it is only the asset received that is to be valued. In-as-much as therefore the value of the additional shares is derived - if only in part - from that of the existing shares, the decline in the value thereof cannot be excluded or ignored – though only by following the valuation method prescribed under the rules – in arriving at the property by way of additional shares received by the assessee. In our view, the same, on the contrary, provides statutory support, i.e., in principle, to our decision in-as-much as it clarifies that the values of the two, i.e., the original and the additional financial assets (which is how the same are referred to in the said provision) are interlinked and, accordingly, a gain cannot be computed independent of each other. It is in fact in acknowledgment thereof that the Legislature has considered it proper and necessary to provide for determination of cost in such cases, i.e., for uniform application. The same though would operate for the purpose of computing capital gains, which would arise on the subsequent transfer of such assets. We have already noted an internal consistency between the two sets of provisions in-as-much as section 49(4) stands simultaneously incorporated to deem the value adopted or taken for the purpose of section 56(2)(vii) (or (viia)) as the cost of acquisition of the relevant asset (refer para 4.1). In fact, the argument becomes irrelevant in view of our decision holding that section 56(2)(vii) shall not have effect, irrespective of the value at which the additional shares are allotted, where and to the extent they are so on the strength of and against the existing shareholdings, made uniformly or subject to adequate pricing. Much was made before us of the Revenue not treating the transaction as a rights issue of shares, as well as of the power of the tribunal in entertaining such a plea, even where taken before it for the first time, including qua the admission of additional evidence. We have already clarified the same to be not a rights issue, i.e., in the strict sense of the term, also stating our reasons, on the basis of admitted facts, therefore. The plea is also rendered inconsequential in view of our afore-said decision. This would also meet the assessee’s argument of it becoming, as a result of the transaction, poorer in-as-much as the value of his holding witnesses a decline after taking into account the payment made for the acquisition of the additional shares. The said argument thus, rather than detracting from lends further support to our decision. The assessee’s argument, with reference to the shares in the resulting company received by a shareholder on demerger, which is without consideration, would thus also be of no moment. The same is again misconceived in-asmuch as the shareholder only receives the value of his existing holding in the form of the shares in the resulting company;
++ we may next meet the various arguments advanced by either side. The assessee claims of section being not per se applicable as neither is there any transfer in its favour nor is the issuer-company the owner of the shares, which stand acquired by way of subscription. We are unable to appreciate the argument. How else, we wonder, is the issued capital in a company supposed to be acquired? The section nowhere stipulates ‘transfer’ as the prescribed mode of acquisition. The transfer of a capital asset is even otherwise a relevant consideration in respect of income by way of capital gains, chargeable u/s.45. A parallel, if at all, in-as-much as the provision, which is to be considered as valid, was required to be placed in perspective and within the scheme of the Act, could be drawn to the deeming provisions of its Chapter VI titled ‘Aggregation of income and set off or carry forward of loss’. An investment or asset found not recorded, wholly or partly, in the books of account maintained by the assessee (for any source of income), and in respect of acquisition or ownership of which he is unable to furnish a satisfactory explanation, i.e., as to the nature and source of acquisition, the value thereof or the excess (unrecorded) value, as the case may be, is deemed as the assessee’s income. The receipt of an asset by the assessee, and in his own right, is, on the other hand, the very basis or the edifice on which the provision of section 56(2)(vii) rests, so that it proceeds on the basis or the footing of the burden of the Revenue being satisfied. The receipt of a capital asset is accordingly made the basis or the condition for the charge to tax as income, unless falling under any of the excepted categories, and which it would be noted is a valid basis u/s. 2(45) r/w s.5. It is this in fact that had led us to state earlier of the receipt (of an asset) as having been adopted as the basis or the condition of deeming as income u/s. 56(2)(vii) (or clauses (v) and (vi)), and of the provision as being on a firm footing. What the provision essentially does is to widen the scope of the afore-referred provisions of Chapter VI, which is essentially a statutory recognition of the rules of evidence, even further. A share does not exist prior to its allotment, and in that sense comes into existence only on its allotment. Allotment of a share is only the appropriation of the authorized share capital, being un-appropriated, to a particular person. In nutshell, the difference between the issue of a share to a subscriber and a purchase of a share from an existing shareholder is the difference between the creation and transfer of a chose in action. How could, therefore, purchase be equated with allotment? In fact, the purchase or transfer implies existence of a property, while the shares, where out of un-appropriated capital, come into existence only on their allotment. It becomes, thus, in the context of the provision, completely irrelevant and of no consequence that the shares in the issuing company are not its property, and that it does not become, therefore, any poorer as a result of the allotment of shares therein. ‘Receipt’ is a word or term of wide import, and would include acquisition of the subject matter of receipt – defined capital assets in the present context, by modes other than by way of transfer as well. We find no reason to limit or restrict the scope of the word ‘receipt’ in the provision to cases of ‘transfer’ only. Doing so would not only amount to reading down the provision, which the tribunal is even otherwise not competent to, being not a court of law, but reading it in a manner totally inconsistent with the unambiguous language and the clear intent (of the Legislature) conveyed thereby, but also its context as well as the drift of section, in complete violence thereto;

++ we have already found receipt as a valid basis for deeming income, which is supported by the principles of common law jurisprudence. That ‘income’ under the Act is a word or term of wide import, and would include anything which comes in or results in gain is also well settled. The provision casts exceptions, again as afore-noted, where in the normal course considerations other than financial/monetary are at play, so that it applies to commercial transactions for which an arm’s length basis can be reasonably regarded as the normative basis for conducting or concluding transactions. Further, even the official pronouncements, which are not to be read as one does a statute, do not in any manner detract from or operate to dilute the rigor of the section; the same itself explaining it as an anti-abuse measure. In fact, even the assessee’s case is limited to right shares only, and does not speak of any other capital asset covered by the provision, including shares and securities. We have already explained that to the extent the shares subscribed to are right shares, i.e., allotted pro-rata on the basis of the existing share-holding (as on a cutoff date), the provision, though per se applicable, does not operate adversely. A disproportionate allotment, which cannot, therefore, strictly be regarded as right shares, though could be allotted under a rights issue, would however invite the rigor of the provision, i.e., to that extent. All that is logical relevant, yielding insight into the purpose and object for and toward which the amendment stands brought, should be admissible. The court cannot read anything into a statutory provision which is plain and unambiguous; a statute being an edict of the Legislature. The language employed in a statue is a determinative factor of the legislative intent, the foundational basis of any interpretation, is to be found from the words used by the Legislature itself. The principle is in fact well settled and trite (refer Padmasundra Rao and others vs. State of Tamil Nadu (2002-TIOL-986-SC-MISC-CB); and Britannia Industries Ltd. vs. CIT (2005-TIOL-125-SC-IT). As explained in Surat Art Silk Cloth Mfrs. Assoc., the consequences cannot alter the meaning of a statutory provision where such meaning is plain and unambiguous, though could certainly help to fix its meaning in case of doubt and ambiguity. The amendment/s under reference, as explained in the Finance Minister’s speech itself while introducing the provision, follows the abolition of the Gift Tax Act which, as also observed earlier, sought to bring the difference in the consideration to tax in the hands of the donor. That the said Act, together with the Wealth Tax Act and the Act form an integrated code is well settled. ‘Income’ under the Act, it is again well settled, is a word of widest amplitude, and could include gains derived in any manner. To our mind, therefore, the provisions/s, though no doubt a charging provision, is an extension of the deeming provisions of Chapter VI of the Act, laying down the statutory rules of evidence, incorporating the principles of common law jurisprudence. In sum, as also in fine, the provision, brought as an anti-abuse measure, only seeks to tax the understatement in consideration as the income in the hands of the recipient as against the donor in the case of Gift Tax Act, since no longer in force, particularly considering the burden that the Revenue would otherwise be called upon to discharge, i.e., to prove otherwise, even as the receipt of the asset by the assessee is established. No ambiguity or absurdity or unintended consequence has been either observed by us or brought to our notice, even as we have endeavoured to examine the provision from all angles; it being well excepted, also excluding cases of business reorganization. The provision is well founded, even as it is settled that hardship in a case would not by itself lead to supplying casus omissus or reading down the provision. In fact, we have also observed the same to be in accord with the trend in the legislative field in the recent past where in view of the increasing complexity of business or economic transactions, fair market value, also providing rules for its determination, is being increasingly adopted for uniform application as a basis for commercial transactions for the purpose of taxing statutes. The reliance on the argument made in this regard would thus be of no assistance to the assessee. No property however being passed on to the assessee in the instant case, i.e., on the allotment of the additional shares, no addition in terms of the provision itself shall arise in the facts of the case. We accordingly answer the question raised at the beginning of this order in the negative. In view of the foregoing, therefore, the provision of s. 56(2)(vii)(c), in the facts and circumstances of the case, shall not apply and, hence, the amount of Rs.27,89,02,160/- cannot be assessed as income in the hands of the assessee on the ground of inadequate consideration. This answers ground nos. 2 to 4. Ground # 1 stands dismissed as not pressed. We decide accordingly. The assessee has also moved a stay application. In view of our having decided the appeal itself, the same becomes infructuous. In the result, the assessee’s appeal is partly allowed and stay application is dismissed as infructuous.

No comments:

Can GST Under RCM Not Charged and Paid from FY 2017-18 to October 2024 be Settled in FY 2024-25?

 In a recent and significant update to GST regulations, registered persons in India can now clear unpaid Reverse Charge Mechanism (RCM) liab...