Saturday, 29 September 2018

No penalty on alleged ‘kickbacks’ under Volcker report; Sec. 263 revision upheld for hawala purchases

ITAT: No penalty on alleged ‘kickbacks’ under Volcker report; Highlights non-bindingness of UN resolution


Pune ITAT deletes penalty levy u/s. 271(1)(c) with respect to Sec. 37(1) disallowance confirmed in quantum appeal for payments made to Dubai and Jordan entities towards transportation/aftersales services etc. during AYs 2002-03 & 2003-04 by assessee in connection with its export sales; Relying on UN Council’s Volcker Committee Report (VCR) (whereby assessee’s name was found in the list of records of VCR), AO had alleged these payments as the kickbacks paid to the Iraq Authorities and accordingly disallowed assessee’s claim u/s. 37, however, ITAT had confirmed the disallowance in quantum appeal only on the ground of failure to discharge of onus; Firstly, ITAT notes that “it is not the case that the AO is in possession of some incriminating evidences to prove that the services are not rendered by the said Dubai/Jordan entities or assessee paid kickbacks to Iraqi Authorities”, also notes that similar disallowance stand allowed in favour of the assessee except in this case of the assessee where addition was confirmed mainly due to the failure in discharge of onus.”; Next, ITAT holds that no international agreements/conventions/treaties/UN Resolution-986 etc. are not binding on the citizens of India, thus rules that the failure of the assessee in not complying with the UN Resolution-986 do not constitute an “offence” for the purpose of Explanation 1 to section 37(1) of the Act; Moreover, ITAT takes note of debatability of the issue, notes that the allowability of the payments made to these entities u/s.37(1) had attracted attention of the various benches of the Tribunal and Court
HC: Upholds CIT’s revision, disallows hawala purchases based on VAT Dept info
Bombay HC upholds CIT’s revisionary proceeding u/s 263 during AY 2011-12 since the AO had failed to enquire about non-genuine purchases made by the assessee even though very reliable and genuine information was received from the VAT and Sales Tax authorities regarding 'hawala traders' and had erred in not disallowing entire non-genuine purchases; On receipt of information from VAT and Sales Tax Department, the AO called upon the assessee to prove the genuineness of the purchases, even though the assessee failed to furnish information, the AO accepted the assessee’s plea to tax gross profit on said purchases to buy peace and to avoid unending litigation and held that 15% of the said purchases be assessed as income; Takes note of CIT's contention that if the VAT Authorities have declared certain parties or suppliers/dealers as 'hawala operators', then, that is a good ground to initiate the investigation and once the assessee could not produce any material nor he could ensure the presence of the supplier before the AO, there was no reason for the AO to accommodate the assessee in the manner done; HC upholds ITAT’s view that the AO did not make any inquiry with regard to the purchases as to whether the items were actually acquired and installed and whether the party providing the goods were dealing in it and these were bogus purchases; Holds that “there was a clear failure to abide by the statutory mandate and by making an estimate so also accepting a vague and general explanation of the assessee, the assessment has been made, then, it will undoubtedly be erroneous insofar it is prejudicial to the interest of the Revenue ”
HC: Deletes penalty levy on infrastructure co. claiming depreciation on highway project cost
Delhi HC upholds ITAT order and deletes penalty u/s 271(1)(c) on assessee-company (engaged in developing national highway) during AYs 2009-10 to AY 2013-14 for making depreciation claim on highway project cost, though inadmissible by subsequent CBDT circular; Takes note of the debatable issue as to whether depreciation should be claimed on highway project or project expenditure should be amortized over the toll concession period, which was only clarified by CBDT Circular of April 2014; Further notes that subsequent to clarification by CBDT Circular of April 2014 that write off of capitalized expenditure equally over the toll concession period is allowed, assessee withdrew claim of depreciation and submitted revised working, therefore holds assessee's conduct as bonafide ; Notes that owing to highly debatable and contentious issues, CBDT had felt the need to clarify the issue
ITAT: Denies exemption u/s 54/54F on 'two' non-adjacent residential flats
Delhi ITAT restricts Sec.54/54F benefit to individual - assessee during AY 2013-14 to one out of the two residential flats purchased, rules that two flats can be construed as 'a residential house' u/s 54/54F only if they have been purchased to be use as one and are adjacent to each other with common facilities; Holds that assessee's two different residential flats which are not adjacent and are on two different storeys cannot constitute “a residential house” ; Relies on Delhi HC ruling in Gita Duggal remarks that "exemption if at all which can be claimed by the assessee in terms of Section 54F would be only with respect to one of the flat only.", also relies on Punjab and Haryana HC in Pavan Arya ; However with respect to denying exemption on the ground that tower in which the flats were purchased, the lift was not installed and the project was still not completed, ITAT holds that "...assessee has made the entire payment and flat has been in complete possession of the assessee" and simply because certain finishing work has not been done it cannot be held that exemption u/s.54F should be denied.

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