Bombay High Court
The Bombay Dyeing And Mfg. Co.Ltd vs The Deputy Commissioner Of I-Tax ... on 14 July, 2023
Bench: K.R. Shriram, Firdosh Phiroze Pooniwalla
2023:BHC-OS:6527-DB
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Digitally
signed by
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
TRUSHA
TRUSHA TUSHAR
TUSHAR MOHITE
ORDINARY ORIGINAL CIVIL JURISDICTION
MOHITE Date:
2023.07.14
11:16:36
+0530
WRIT PETITION NO.2537 OF 1999
The Bombay Dyeing & Manufacturing Co. Ltd.
a company incorporated under the Companies
Act, 1886 and having its Registered Office
at Neville House, Ballard Estate, Bombay 400 001 ..... Petitioner
Vs.
1. H.D. Trivedi, Deputy Commissioner
of Income Tax, Central Circle 8,
having his office at Old C.G.O.
Annexe Building, Maharsi Karve Road,
Bombay 400 020.
2. H.C.Parekh, Commissioner of
Income Tax, Central-1, Bombay
having his office at old C.G.O.
Annexe Building,
Maharshi Karve Road,
Bombay 400 020.
3. Union of India ..... Respondents
Mr.Madhur Agrawal i/b Mr.Atul K. Jasani for the Petitioner
Mr.Suresh Kumar for the Respondents
CORAM: K.R. SHRIRAM, J &
FIRDOSH P. POONIWALLA, J.
RESERVED ON: 23rd JUNE 2023
PRONOUNCED ON: 14th JULY 2023
JUDGMENT (PER FIRDOSH P. POONIWALLA, J):
1. The present Writ Petition challenges the legality and
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validity of the orders passed by Respondent no.2 determining the
amount of tax payable by the Petitioner pursuant to a declaration
filed under the Kar Vivadh Samadhan Scheme, 1998 ("KVSS")
introduced by Finance (No.2) Act, 1998 ("Finance Act"). In
particular, the Petitioner has challenged the Certificate dated
25.02.1999 issued by Respondent no.2 in terms of sub-section (1) of
Section 90 of the Finance Act, Order dated 17.03.1999 passed by
Respondent no.2 rejecting the Petitioner's Rectification Application
and a Certificate dated 02.08.1999 issued by Respondent no.2 under
Section 90(2), read with Section 91, of the Finance Act.
2. The Petitioner is a public limited company which carries
on the business interalia of manufacture and sale of textiles. The
Petitioner had filed a Writ Petition in this Court, being Writ Petition
No.2007 of 1991, wherein it had challenged interalia the validity of
Section 115J of the Income Tax Act, 1961 ("the Act"), the validity of
CBDT Circular No.495 dated 22.09.1987 and the manner in which
Respondents ought to apply the said Section in the matter of
working out the set off of brought forward depreciation and
investment allowance. In the said Writ Petition, Rule was issued by
this Court on 26.06.1991. While issuing Rule, this Court passed an
interim order whereunder the Petitioner was permitted to pay
advance tax or self assessment tax and/or file its return of income in
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accordance with the third interpretation given in the said Writ
Petition to the provisions of Section 115J of the Act. Further, the
Respondents were permitted to proceed with the assessment but
could not serve any notice of demand on the Petitioner pending
further orders in the said Writ Petition. Interest under Sections
234A. 234B and 234C of the Act as well as additional tax under
section 143(1A) of the Act were to be paid in accordance with the
third interpretation set out in the Petition. The Petitioner was also
to furnish a bank guarantee of a nationalised bank for 50% of
differential tax less advance tax and tax deducted at source for
Assessment Year 1991-92 on the basis of the difference between the
interpretation of Section 115J as per the said Circular No.495 dated
22.09.1987 issued by the Central Board of Direct Taxes and the
third interpretation, which bank guarantee was to be furnished
within three months from the date of the determination and which
was so furnished.
3. On 20.12.1991, the Petitioner filed its Return of Income
for Assessment Year 1991-92. The Petitioner returned a nil income
and on account of the Advance Tax of Rs.4,51,50,000/- paid and the
tax deducted at source of Rs.1,01,74,620/- the Petitioner claimed a
refund of Rs.5,53,24,620/- in the Return as filed on 20.12.1991.
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4. Respondent no.1 processed the Return filed on
20.12.1991 and made an intimation under section 143(1)(a).
Respondent no.1, by his letter dated 11.06.1992, intimated to the
Petitioner that the total tax, including interest under section 234B
was determined at Rs.19,23,82,029/- and after allowing for credit of
advance tax and tax deducted at source aggregating to
Rs.5,47,97,545/- a sum of Rs.13,75,84,484/- was payable and
accordingly, a demand was raised. The Petitioner was called upon to
furnish a bank guarantee for a sum of Rs.6,87,92,242/- being 50% of
the said demand.
5. The Petitioner, by its letter dated 27.11.1992, applied for
rectification of certain errors. The said application was disposed by
an Order dated 31.12.1992 made under section 154 of the Act.
Respondent no.1 determined the total income at Rs.6,51,19,488/-
and the tax payable thereon at Rs.3,59,45,957/-. After giving credit
for advance tax of Rs.4,51,50,000/- and tax deducted at source of
Rs.96,47,545/-, aggregating to Rs.5,47,97,545/-, a refund of
Rs.1,88,51,588/- was determined. Respondent no.1 also granted
interest to the Petitioner under Section 244A of the Act of a sum of
Rs.45,24,384/- and accordingly determined the total sum refundable
at Rs.2,33,75,972/-. This refund was adjusted against a demand for
the Assessment Year 1990-91.
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6. Being aggrieved by the said Order dated 31.12.1992, the
Petitioner filed an Appeal to the Commissioner of Income tax
(Appeals). The Petitioner also filed an application for rectification by
its letter dated 24.05.1993.
7. Respondent no.1, by an Order dated 15.07.1993,
rectified his earlier order and granted an additional credit for tax
deducted at source of Rs.5,24,909/- as well as recomputed the
interest allowable under section 244A. Accordingly a further refund
of Rs.16,30,205/- was worked out and the same was received by the
Petitioner.
8. The Petitioner's Appeal challenging the said Order dated
31.12.1992 was allowed by the Commissioner of Income Tax
(Appeals) by his Order dated 02.09.1993. On further Appeal by the
Revenue to the ITAT, by an Order dated 22.12.1997, the ITAT
restored the matter to the file of the Commissioner of Income Tax
(Appeals) with a direction that the Appeal be disposed de novo.
9. By a letter dated 31.03.1994, Respondent no.1 intimated
to the Petitioner that its assessment for the Assessment Year 1991-
1992 had been completed under Section 143(3) of the Act and the
total income was determined at Rs.29,04,54,928/-.
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10. Respondent no.1, thereafter, by his letter dated
16.11.1994 addressed to the Petitioner, worked out the tax payable
on a provisional basis at Rs.11,60,82,920/- and called upon the
Petitioner to furnish a bank guarantee of 50% thereof viz.,
Rs.5,80,41,460/- within ten days of the receipt of the said letter.
11. Thereafter, pursuant to reopening of the Petitioner's
assessment under Section 148 of the Act, the total income of the
Petitioner was revised to Rs.31,96,52,478/- and a demand of
Rs.17,84,62,709/- was raised.
12. The Petitioner decided to take advantage of the KVSS to
put an end to the disputes. Therefore, by its letter dated 30.12.1998
addressed to Respondent no.2, Petitioner forwarded a declaration
under the KVSS for the Assessment Year 1991-92. The tax arrears
outstanding as on 31.03.1998 for the Assessment Year 1991-92
were computed at Rs.17,84,62,709/- consisting of tax demand of
Rs.9,17,17,686/-, interest of Rs.6,17,38,846/- and another sum of
Rs.2,50,06,177/- which was the refund inclusive of interest granted
under section 244A and which was received pursuant to the
intimation made. The disputed income was computed at
Rs.19,93,86,274/- on which the tax liability under the KVSS was
determined at Rs.6,97,85,196/-. The computation of tax liability
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under the KVSS, as done by the Petitioner, is as under:
(A) Computation of Disputed Tax Rs.
Tax & Surcharge Payable 147040140
Less: Advance Tax & Tax 55322454
Deducted at Source
Net Tax Payable 91717686
Disputed Tax 91717686
(B) Computation of Disputed Income
Disputed Tax 91717686
Disputed Income 199386273.9
Say 199386274
(C) Computation of Tax Payable under the Kar Vivad
Samadhan Scheme, 1998
Disputed Income 199386274
Tax liability under Kar Vivad Samadhan Scheme, 1998
69785195.9
Tax payable under the Kar Vivad 69785196
Samadhan Scheme, 1998
13. Respondent no.2 issued as per the KVSS, a Certificate
dated 25.02.1999 under sub-section (1) of Section 90 of the Finance
Act and determined the tax arrears at Rs.17,84,62,709/- in
agreement with the Petitioner's determination. However,
Respondent no.2 computed the tax payable under KVSS at
Rs.8,88,11,635/-. The Petitioner was called upon to make payment
of the said sum of Rs.8,88,11,635/- within a period of thirty days
from the date of the said Certificate. Whilst determining the
disputed tax, Respondent no.2 determined the tax paid at
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Rs.3,03,16,277/- as against the Petitioner's claim that the total tax
paid was Rs.5,53,22,454/-. According to Respondent no.2, from the
advance tax paid and tax deducted at source aggregating to
Rs.5,53,22,454/-, the refund of Rs.2,50,06,177/- granted pursuant
to the intimation under section 143(1)(a) had to be reduced. The
calculation made by Respondent no.2 is as under:
KAR VIVAD SAMADHAN SCHEME, 1998
A) Assessed income Rs.31,96,52,478
B) Assessed tax thereon (including S.C.) Rs.14,70,40,140
C) Taxes paid:
TDS & advance tax Rs.5,53,22,454
Less: R.O.issued as
per 143 (1)(a) Rs.2,50,06,177
------------------------
Rs. 3,03,16,277
Tax arrears (disputed tax) Rs.11,67,23,863
When tax is Rs.14,70,40,140/- income is Rs.31,96,52,478
When tax is Rs. 3,03,16,277/- income is Rs. 6,59,04,950
Disputed income Rs.25,37,47,528
Hence amount payable under KVSS 1998
@ 35% of disputed income Rs. 8,88,11,635
14. The Petitioner, by its letter dated 03.03.1999 addressed
to Respondent no.2, pointed out that the difference between the
disputed income and the tax payable pursuant to the declaration
under KVSS as determined by Respondent no.2, and as per the
declaration filed, arose on account of the fact that from the advance
tax paid and tax deducted at source aggregating to Rs.5,53,22,454/-
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Respondent no.1 had deducted the refund granted to the Petitioner
of Rs.2,50,06,177/-. It was further submitted that assuming such
refund was to be deducted, the interest granted under section 244A
of the Act of Rs.56,29,680/- which formed a part of the said refund,
could in no event have been reduced. The Petitioner further
submitted that the adjustment so made was not in accordance with
the provisions of the KVSS and that Respondent no.2 was required
to amend his Certificate and issue a fresh certificate.
15. Respondent no.2, by his Order dated 17.03.1999,
rejected the Petitioner's rectification application. According to
Respondent no.2, the refund of Rs.2,50,06,177/- granted pursuant
to the intimation made was to be deducted from the tax paid for
arriving at the amount of net payment of tax, and as the adjustment
was in accordance with the KVSS, there was no merit in the
rectification application.
16. It is the case of the Petitioner that, as the last date of
payment of tax was 27.03.1999, the Petitioner had no option but to
make the payment, and, accordingly, the Petitioner paid a sum of
Rs.8,88,11,635/- on 24.03.1999.
17. The Petitioner, by its letter dated 30.03.1999 addressed
to Respondent no.2, pointed out that the Petitioner had, without
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prejudice to its rights and contentions, paid the amount of
Rs.8,88,11,635/- on 24.03.1999 and furnished the proof of payment
of the said sum. Respondent no.2 was requested to issue a
Certificate under section 90(2) of the Finance Act.
18. Further, in accordance with the provisions of section
90(4) of the Finance Act, the Petitioner applied to this Court to
withdraw Writ Petition No.2007 of 1991 and this Court, by its Order
dated 22.06.1999, permitted the withdrawal of the said Petition.
19. The Petitioner filed a copy of the said Order with
Respondent no.2, who thereafter issued a Certificate dated
02.08.1999 under Section 90(2), read with Section 91, of the
Finance Act.
20. The present Writ Petition was filed on 17.09.1999. On
behalf of the Respondents, Respondent no.2 filed an Affidavit dated
12.11.1999 opposing the granting of any reliefs in the Petition. By
an Order dated 06.12.1999, this Court issued Rule on the Petition.
21. Although raised in the Writ Petition, Mr.Agrawal did not
press the submission that the amount of tax refund of
Rs.1,93,76,497/- should not have been reduced to determine the
amount of tax paid by the Petitioner.
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22. Mr.Agrawal, however, submitted that, even if it is held
that the amount of tax refunded to the Petitioner is to be reduced
while determining the amount of disputed tax, then, also, only the
amount of Rs.193,76,497/-, being the tax refund, should be reduced
and not the amount of interest under Section 244A of
Rs.56,29,680/-. In this context, Mr.Agrawal submitted that, from
the tax paid by the Petitioner of Rs.553,22,454/-, the tax which had
been refunded to the Petitioner is only Rs.193,76,497/- and as the
Revenue had the benefit of the said sum of Rs.193,76,497/- from the
date of payment to the date of refund, interest on the said amount of
Rs.56,29,680/- had been paid to the Petitioner under Section 244A
of the Act. He submitted that it is undisputed that what was
refunded to the Petitioner by way of tax is only the amount of
Rs.193,76,497/- and, therefore, in any view of the matter, it is only
this amount which should be reduced to determine the amount of
tax paid by the assessee and not the amount of interest. Mr.Agrawal
further submitted that, if the amount of interest is also reduced
while determining the amount of tax paid by the assessee, it may
lead to absurdity. In this context, Mr.Agrawal gave an example that,
if the assessee had paid tax of Rs.1,00,000/- and the whole amount
had been refunded to the assessee along with interest of Rs.15,000/-
under section 244A of the Act, in such a case it may be held that the
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assessee has not paid any tax and therefore, the tax paid by the
assessee would be 'NIL' as the whole of the tax paid of Rs.1,00,000/-
had already been refunded to the assessee. However, if the
argument of the Respondents is to be accepted, then the amount of
tax paid by the assessee would be determined as negative, i.e. -
Rs.15,000/- because according to the revenue, although the assessee
has paid tax of Rs.1,00,000/-, refund to the assessee has been
granted of Rs.1,15,000/- and therefore, tax paid by the assessee is
negative, i.e. - Rs.15,000/-. He submitted that it would be absurd to
say that the tax paid by the assessee is a negative amount as it is not
possible for an assessee to pay tax in the negative.
23. In these circumstances, Mr.Agrawal submitted that even
if one was to reduce the amount of refund granted to the assessee
from the tax paid by an assessee, the said reduction should be
restricted to the refund of tax and not refund of interest.
24. On the other hand, Mr.Suresh Kumar, the learned
Counsel for the Respondents, reiterated the contents of the Affidavit
in Reply dated 12.11.1999 filed by Respondent no.2 and in
particular, the contents of sub-paragraphs (a), (b) and (c) of
paragraph 6 of the said Affidavit, which read as under:-
(a) The "Disputed Tax" means the total tax
determined and payable in respect of the
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assessment year but which remains unpaid as on
the date of declaration under Kar Vivad
Samadhan Scheme. It is true that in the case of
the Petitioner the income assessed for the A.Y.
1991-92 was of Rs.31,96,52,478/- and tax
determined on the same was of
Rs.14,70,40,140/-. The assessee had paid
Rs.5,53,22,454/- by way of advance tax and tax
deducted at source. The assessee was however
issued refund of Rs.2,50,06,177/- which accrued
to the assessee as a result of processing of the
assessee's return u/s. 143(1)(a) of the Act. This
refund amount of Rs.2,50,06,177/- comprised of
Rs.1,93,76,497/- being the amount of excess
prepaid taxes and Rs.56,29,680/- being the
amount of interest on this amount of
Rs.1,93,76,497/-. Thus though the assessee had
paid Rs.5,53,22,454/- by way of advance tax and
tax deducted at source, an amount of
Rs.2,50,06,177/- was refunded back to the
assessee as per the intimation u/s. 143(1)(a) of
the Act much prior in time to making of the
assessment and thereby determining the assessed
income and the tax payable thereof. The tax paid
in advance by the assessee was therefore
Rs.3,03,16,277/-only (5,53,22454- 2,50,06,177).
On the day of assessee's filing the declaration
under the Kar Vivad Samadhan Scheme the tax
remaining unpaid i.e. the disputed tax was
therefore of Rs.11,67,23,863/- which is the
resultant figure arrived at by deducting
Rs.3,03,16,277/- being the tax paid in advance
from Rs.14,70,40,140/- being the amount of
assessed tax. As per the definition the "disputed
tax" means the tax determined and payable but
which remains unpaid. In view of the fact that in
this case an amount of Rs.2,50,06,177/- was
already refunded back to the assessee
(Rs.1,93,76,497/- being the amount of the excess
prepaid taxes and Rs.56,29,680/- being the
amount of interest on it) from the prepaid taxes
of Rs.5,53,22,454/- obviously while calculating
the tax remaining unpaid the deduction of the
amount of Rs.3,03,16,277/- was given as the
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taxes already paid from the tax determined and
payable.
(b) In this case the tax determined and
payable was of Rs.14,70,40,140/- and the on the
day of declaration under Kar Vivad Samadhan
Scheme tax remaining unpaid was of
Rs.11,67,23,863/- as already an amount of
Rs.2,50,06,177/- was refunded back to the
assessee.
(c) It is obvious that while taking into
account the amount of the prepaid taxes, the
amount of tax already refunded back (out of the
prepaid taxes) to the assessee has to be deducted
from the amount of the prepaid tax and this fact
was intimated to the assessee while rejecting its
application for the rectification."
25. In our view, the submissions made on behalf of the
Petitioner do not have any merit. Section 88(a)(i) of the Finance
Act reads as under:
88:- Settlement of tax payable:- Subject to the
provisions of this Scheme, where any person
makes, on or after the 1st day of September, 1998,
but on or before the 31st day of December, 1998, a
declaration to the designated authority in
accordance with the provisions of section 89 in
respect of tax arrear, then, notwithstanding
anything contained in any direct tax enactment
or indirect tax enactment or any other provision
of any law for the time being in force, the amount
payable under this Scheme by the declarant shall
be determined at the rates specified hereunder,
namely:-
"(a) where the tax arrear is payable under the
Income-tax Act, 1961 (43 of 1961), -
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(i) in the case of a declarant, being a company or a
firm, at the rate of thirty-five per cent of the
disputed income."
26. Under the provisions of section 88(a)(i) of the Finance
Act, on the basis of the tax arrears / disputed tax, the disputed
income of the assessee has to be worked out, and, in order to claim
benefits under KVSS, the assessee, if it is a company or a firm, has to
pay taxes at the rate of thirty-five per cent of the disputed income so
worked out.
27. Section 87(e) of the Finance Act defines disputed income
as under:-
87(e) "disputed income", in relation
to an assessment year, means the
whole or so much of the total income
as is relatable to the disputed tax."
28. Section 87(f) of the Finance Act defines disputed tax as
under:
87(f) "disputed tax" means the total
tax determined and payable, in
respect of an assessment year under
any direct tax enactment but which
remains unpaid as on the date of
making the declaration under section
88."
29. On the basis of the said definitions of disputed tax and
disputed income, it is clear that, in order to arrive at the disputed
tax, the total assessed tax for that particular year would have to be
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worked out, and, from the same, the taxes which may have been
paid by the assessee have to be deducted. That disputed tax has to
be total tax determined and payable but which remains unpaid, as
per the provisions of Section 88(f), 'tax which remains unpaid' as on
the date of making declaration. To calculate tax which remains
unpaid, it is obvious that, whilst deducting from the total assessed
tax the tax already paid, effect would have to be given to any refund
issued by the Revenue to the Assessee and to any interest paid
thereon by the Revenue to the Assessee. If effect is not given to the
said Refund and interest paid by the Revenue to the Assessee, then
the figure of disputed tax which would be arrived at would not be tax
which remained unpaid.
30. It is true that income of the Petitioner assessed for A.Y.
1991-92 was of Rs.31,96,52,478/- and the tax determined on the
same was of Rs.14,70,40,140/-. The Petitioner had paid
Rs.5,53,22,454/- by way of advance tax and tax deducted at source.
The Petitioner was, however, issued refund of Rs.2,50,06,177/-
which accrued to the Petitioner as a result of processing the
Petitioner's return under Section 143(1)(a) of the Act. This refund
amount of Rs.2,50,06,177/- comprised of Rs.1,93,76,497/- being the
amount of excess prepaid taxes and Rs.56,29,680/- being the
amount of interest on this amount of Rs.1,93,76,497/-. Thus though
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the Petitioner had paid Rs.5,53,22,454/- by way of advance tax and
TDS, an amount of Rs.2,50,06,177/- was refunded to the Petitioner
as per the intimation under Section 143(1)(a) of the Act much prior
in time to making of the assessment and thereby determining the
assessed income and the tax payable thereon. The tax paid in
advance by the Petitioner was, therefore, Rs.3,03,16,277/- only
(Rs.5,53,22,454/- - Rs.2,50,06,177/-). On the day of the Petitioner's
filling the declaration under KVSS the tax remaining unpaid, i.e., the
disputed tax was, therefore, Rs. 11,67,23,863/- which is the
resultant figure arrived at by deducting Rs.3,03,16,277/- being the
tax paid in advance from Rs.14,70,40,140/- being the amount of
assessed tax. As per the definition, the disputed tax means the tax
determined and payable but which remains unpaid. In view of the
fact that in this case an amount of Rs.2,50,06,177/- was already
refunded back to the Petitioner (Rs.1,93,76,497/- being the amount
of the excess prepaid taxes and Rs.56,29,680/- being the amount of
interest on it) from the prepaid taxes of Rs.5,53,22,454/- obviously
while calculating the tax remaining unpaid the deduction of the
amount of Rs.3,03,16,277/- only has to be given as the taxes already
paid from the tax determined and payable.
31. In these circumstances, in our view, Respondent no.2,
whilst calculating the disputed tax, has correctly taken the assessed
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tax at Rs.14,70,40,140/-, and deducted the tax paid by the
Petitioner by way of advance tax and tax deducted at source of
Rs.5,53,22,454/- after deducting therefrom a sum of
Rs.2,50,06,177/- which had been paid to the Petitioner by way of
refund and interest under section 143 (1)(a) of the Act. After
deducting the said sum of Rs.2,50,06,177/- from the tax paid of
Rs.5,53,22,454/-, the Respondent no.2 has correctly arrived at the
figure of Rs.3,03,16,277/- as the amount of tax paid. After deducting
the said amount of Rs.3,03,16,277/- from the said sum of
Rs.14,70,40,140/-, Respondent no.2 has correctly calculated the
disputed tax as Rs.11,67,23,863/- and, on the basis of the said sum,
has correctly worked out the amount payable by the Petitioner
under the KVSS as Rs.8,88,11,635/-. In our view, the said
calculation made by Respondent no.2 is in consonance with the
provisions of the Finance Act and cannot be faulted.
32. Further, while considering this argument of the
Petitioner, it is important to keep in mind the fact that the Revenue
refunded tax to the Petitioner, and paid interest thereon, because
the Petitioner had not disclosed and calculated tax properly. This
being the situation, the Petitioner cannot take advantage of its own
wrong and claim that the interest which has been paid to it should
not be reduced while computing the disputed tax. We are not
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inclined to entertain such an argument at all, and, in any case,
definitely not whilst exercising our Writ Jurisdiction.
33. For all the aforesaid reasons, the Writ Petition is hereby
dismissed and the Rule issued by this Court is discharged.
34. There shall be no order as to costs.
(FIRDOSH P.POONIWALLA, J.) (K.R. SHRIRAM, J.)
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