Madras High Court
Sampath Thiruvalan vs The Assessment Unit on 3 January, 2025
Author: C.Saravanan
Bench: C.Saravanan
W.P.(MD)No.3584 of 2024
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
Reserved on 24.07.2024
Pronounced on 03.01.2025
CORAM :
THE HONOURABLE MR.JUSTICE C.SARAVANAN
W.P.(MD)No.3584 of 2024
and
W.M.P.(MD)Nos.3537, 3538, 3539 of 2024
Sampath Thiruvalan ... Petitioner
Vs.
1.The Assessment Unit,
Income Tax Department,
New Delhi.
2.The Income Tax Officer,
Ward 1(1),
Trichy,
Trichy Main Building, Williams Road,
Contonment,
Trichy – 620 015. ... Respondents
Prayer: Writ Petition filed under Article 226 of Constitution of India for
issuance of a Writ of Certiorari, to call for the records in the file of the
respondents and quash the impugned order under Section 147 r.w.s. 144B of
the Income Tax Act, 1961 in PAN AADPT1305L dated 03.01.2024 in DIN
ITBA/AST/S/147/2023-14/1059326216(1) by the first respondent for the A.Y.
2018-19.
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Page No.1 of 24
W.P.(MD)No.3584 of 2024
For Petitioners : Mr.N.Murali Kumaran
Senior Counsel for
M/s.NV.Lakshmi
For Respondents : Mr.N.Dilip Kumar
Senior Standing Counsel
ORDER
In this Writ Petition, the petitioner has challenged the impugned order
dated 03.01.2024 passed by the first respondent under Section 147 & 144B of
the Income Tax Act, 1961 for the Assessment Year 2018-2019. The petitioner
has challenged the impugned order on the ground of jurisdiction.
2. By the impugned order, the first respondent has disallowed an amount
of Rs.86,54,545/- which was claimed by the petitioner as deduction towards the
cost of improvement of immovable property with indexation.
3. This case is taken up for final disposal without counter affidavit of the
respondents as only the question of law that arises for consideration in this Writ
Petition is whether the impugned order dated 03.01.2024 passed by the first
respondent pursuant to the order passed by the second respondent under
Section 148A(d) of the Income Tax Act, 1961 on 05.04.2022 is valid or not?
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4. The brief case of the petitioner is that the petitioner had earlier
purchased an immovable property (land) measuring an extent of 2400 sq.ft. (1
ground) for a sum of Rs.6,20,000/- on 15.09.2011 together with stamp duty.
The petitioners claims to have invested a sum of Rs.70,00,000/- for developing
the aforesaid immovable property.
5. The petitioner claims to have sold the aforesaid property after it was
built as a distress sale on 29.08.2017 for a sum of Rs.80,30,500/-.
6. The petitioner appears to have received a sum of Rs.36,10,413/-
directly in cash and in cheque from the buyer. The balance sale amount of Rs.
44,20,087/- (i.e., Rs.80,30,500 - Rs.36,10,413) was directly paid by the buyer
to REPCO Bank to settle a loan of the petitioner.
7. The petitioner however failed to file Return of Income under Section
139 of the Income Tax Act, 1961 for the Assessment Year 2018-2019. The
Department had thus received an alert and therefore issued a notice dated
20.03.2022 to the petitioner under Section 148A(b) of the Income Tax Act,
1961 and called upon the petitioner to show cause as to why a notice under
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Section 148 of the Income Tax Act, 1961 should not be served on the
petitioner. The reason appended to the aforesaid notice reads as under:-
SFT-012 (S) Sale by any person of immovable property
SUB REGISTRAR OFFICE MANNACHANALLUR 1
Transaction amount related to the person 80,30,500 &
TDS-194IA (R) TDS Statement – Sales Consideration on
sale of immovable property (Section 194IA) VADIVEL
BALAGANESHAN 1 Amount paid or credited 80,30,500.
8. In response to the same, the petitioner replied back on 28.03.2022.
The petitioner admitted to the sale of the property and the receipt of total
consideration of Rs.80,30,500/-. In the reply, the petitioner has categorically
stated that the sale was a distress sale and that the sale actually resulted in a Net
loss of Rs.15,40,567/- to the petitioner. The Statement of Total Income
enclosed with the aforesaid reply reads as under:-
INCOME FROM CAPITAL GAIN:
LONG TERM CAPITAL GAIN
Sales Value 80,30,500
Less: Index Cost of Acquisition
(620000/184X272) 9,16,522
Less: Cost of Improvement
(7000000/220X272) 86,54,545
_______
95,71,067 95,71,067
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Income from LTCG - 15,40,567
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Gross Total Income (A) - 15,40,567
________
Total Income - 15,40,567
Say - 15,40,567
TAX CALCULATIONS
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Tax Payable Nil
9. Disbelieving the explanation given by the petitioner, the second
respondent proceeded to pass an order under Section 148A(d) of the Income
Tax Act, 1961 on 05.04.2022 followed by a notice under Section 148 of the
Income Tax Act, 1961 on 06.04.2022. The aforeaid Notice issued under
Section 148 of the Income Tax Act, 1961 on 06.04.2022 was followed with
Notices issued under Sections 143(2), 142(1) & 152(1) of the Income Tax Act,
1961 on 15.06.2023, 16.06.2023 & 26.07.2023 respectively.
10. The petitioner has furnished some of the documents called for and
has also replied back. The petitioner has furnished the Bank Statement from
State Bank of India (SBI) from whom the petitioner had purportedly taken a
loan for a sum of Rs.25,00,000/-.
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11. The specific case of the petitioner is that the impugned order dated
03.01.2024 has been passed by the first respondent without jurisdiction. It is
therefore submitted that the impugned order is liable to be quashed as it was
passed pursuant to the order passed by the second respondent under Section
148(d) of the Income Tax Act, 1961 on 05.04.2022.
12. The case of the petitioner is that sum of Rs.47,11,000/- was directly
given as the loan by the firm called M/s.JL Properties and said loan was also
repaid by the petitioner for over a period of time. It is to be noted that the
petitioner himself is a partner of the said partnership concern to whom the
construction activities was entrusted over under the Construction Agreement
dated 22.03.2012.
13. At that stage, the total area of construction was only confined to 2432
sq.ft. i.e., 1504 sq.ft. on the ground floor and 928 sq.ft. on the first floor. The
petitioner claims to have additionally constructed 595 sq.ft. on the second floor
subsequently.
14. Disbelieving the explanation and the documents filed by the
petitioner pursuant to the above notice, the first respondent has concluded that
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the amount of Rs.86,54,545/- had not been properly explained and has thus
concluded as follows:-
4.5 Point wise rebuttal of reply of the assessee including
analysis of any case law relied upon:
From the submission of the assessee, it seen that assessee
has failed to explain the Cost of Improvement with
indexation claimed of Rs.86,54,545/-, even after the final
show cause notice the assessee did not submit the evidence
to explain the cost of Improvement claimed. Thus, the
submission of the assessee has been duly considered but
not found acceptable in absence of any supporting
documentary evidence with respect to the claim of cost of
improvement. In his contention the assessee has stated that
the entire cost of construction cost as unexplained
investment or undisclosed income is not warranted and
requested to drop the taxing proposal in the SCN.
Considering the same, in absence of evidence with respect
to the cost of improvement the contention of the assessee is
not found acceptable.
4.6 Conclusion drawn:
In view of the above discussion, in absence of any
supporting documentary evidence, the transactions in claim
of Indexed cost of improvement is considered sham/
manipulated transactions and the whole of unexplained cost
of improvement of Rs.86,54,545/- up to the extent of sale
consideration of Rs.71,13,978/- after reduce the cost of
acquisition of Rs.9,16,522/- as suggested by the Review
Unit, through which assessee has reduced the capital gain
from sale consideration obtained, hence disallowed the
claim of cost of improvement and the same is treated as
unaccounted income u/s 69A of the I T Act as suggested by
the review unit and added back to the total income for the
year under consideration and taxed in view of the provision
u/s 115BBE.
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15. Arguing further, the learned Senior Counsel for the petitioner would
submit that the impugned order is flawed and is therefore liable to be set aside.
The learned Senior Counsel for the petitioner would submit that the petitioner
should be an opportunity to explain the case afresh. It is submitted that the
petitioner has indeed suffered loss and invested a sum of Rs.25,00,000/- + Rs.
47,11,000/- for putting up the construction and that the petitioner had suffered
a loss of Rs.15,40,567/- from the distress sale.
16. It is further submitted that even otherwise, the invocation of Section
147 of the Income Tax Act, 1961 after the amendments was also without
jurisdiction inasmuch as notice under Section 148 of the Income Tax Act, 1961
as also notice under Section 148A of the Income Tax Act, 1961 were issued
beyond the period of limitation prescribed under Section 151(2) of the Income
Tax Act, 1961.
17. It is submitted that the dispute pertains to the Assessment Year
2018-2019 (relevant Assessment Year 2017-2018). It is submitted that notice
under Section 148 of the Income Tax Act, 1961 ought to have been issued on
or before 31.03.2022, whereas, the notice has been issued under Section 148 of
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the Income Tax Act, 1961 on 06.04.2022. It is submitted that the respondents
have obtained sanction only from the Principal Commissioner of the Income
Tax Department, whereas, the sanction should have been obtained from the
Principal Chief Commissioner of Income Tax Department.
18. The learned Senior Counsel for the petitioner would draw attention to
the proviso to Section 151 of the Income Tax Act, 1961 as it stood prior to
amendment w.e.f. 01.04.2023. It is submitted that sanction prior to 01.04.2023,
under the proviso to Section 151 of the Income Tax Act, 1961 was not obtained
and therefore, there was no jurisdiction to issue a notice without the sanction of
the Principal Chief Commissioner or Principal Director General, or, in their
absence from the Chief Commissioner or Director General, as a period of
three years had already lapsed from the end of the relevant assessment year.
19. That apart, it is submitted that the assessment could not have been
made by Faceless Authority under Section 151A(2) of the Income Tax Act,
1961. It is submitted that invocation of Section 148A(b) of the Income Tax
Act, 1961, on 20.03.2022 was by the Jurisdictional Officer, whereas the
assessment has been made by the Faceless Authority.
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20. It is submitted that by applying the Explanation to Section 147 of the
Income Tax Act, 1961 in the light of the ratio of the Hon'ble Division Bench of
the Bombay High Court in Commissioner of Income-tax-56, Mumbai Vs. Jet
Airways (l) Ltd., [2011] 331 ITR 236 : [2010] 195 Taxmann 117 (Bombay), it
is not open for the respondent to invoke Section 69A of the Income Tax Act,
1961.
21. Adding further, the learned Senior Counsel for the petitioner would
submit that at best, only Section 69 of the Income Tax Act, 1961 could have
been invoked. In any event, the learned Senior Counsel for the petitioner
would submit that the petitioner may be given one opportunity to explain the
investments made by the petitioner in the development of the immovable
property measuring an extent of 3027 sq.ft. From 2011 with proper records on
the land measuring an extent of 2400 sq.ft.
22. The learned Senior Counsel for the petitioner has placed reliance of
the following decisions:-
i. Kankanala Ravindra Reddy Vs. The Income Tax Officer
and others, dated 14.09.2023 passed by the Telegana High
Court in W.P.No.25903 of 2022 etc. batch.
ii. Hexaware Technologies Limited Vs. Assistant
Commissioner of Income Tax and others, dated 03.05.2024
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passed by the Bombay High Court in W.P.No.1778 of 2023.
iii. Martech Peripherals (P.) Ltd. Vs. Deputy Commissioner
of Income-tax, [2017] 394 ITR 733 (Madras) : [2017] 81
taxmann.com 73.
iv. Siemens Financial Services Pvt. Ltd. Vs. Deputy
Commissioner of Income Tax and others, dated 25.08.2023
passed by the Bombay High Court in W.P.No.4888 of 2022.
v. Holiday Developers (P.) Ltd. Vs. Income Tax Officer,
[2024] 159 taxmann.com 178 (Bombay).
23. Per contra, the learned Senior Standing Counsel for the respondents
would submit that Sections 120 read with 124 and 130 of the Income Tax Act,
1961 prescribes the Jurisdiction of Income Tax Authorities, Jurisdiction of
Assessing Officers and Faceless Jurisdiction of Income Tax Authorities
respectively. It is submitted that Section 144B of the Income Tax Act, 1961
provides for faceless assessment of various assessments under Section 143(3)
(Scrutiny Assessment), Section 144 (Best Judgment Assessment) and Section
147 (Reopened Assessment).
24. This Writ Petition is opposed by the learned Senior Standing Counsel
for the respondents on the ground that there is a statutory estoppel against the
petitioner questioning the Assessing Officer under Section 124(3)(a) of the
Income Tax Act, 1961 which reads as under:-
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“124. Jurisdiction of Assessing Officers.—
(1) ......
(2) ......
(3) No person shall be entitled to call in question the
jurisdiction of an Assessing Officer—
(a) where he has made a return under sub-section (1) of
section 115WD or under sub-section (1) of section 139,
after the expiry of one month from the date on which he was
served with a notice under sub-section (1) of section 142 or
sub-section (2) of section 115WE or sub-section (2) of
section 143 or after the completion of the assessment,
whichever is earlier;”
25. It is further submitted that E-Assessment of Income Escaping
Assessment Scheme 2022 provides for automated allocation. Faceless
Jurisdiction of Income Tax Authorities' Scheme, 2022 defines "Automated
Allocation". It is further submitted that in all cases where return is selected for
scrutiny or where it is reopened, the selection is only by way of automation and
the risk management strategy adopted which alone identifies the cases by using
technological tools. Therefore, it is submitted that the contention of the learned
Senior Counsel for the petitioner is completely misconceived.
26. It is submitted that the entire proceedings either under Section 148A
or the reopened assessment under Section 147 were completely faceless. It is
further submitted that the Jurisdictional Assessing Officer or Faceless
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Assessment Officer, conduct proceedings only through virtual mode and no
physical interaction is allowed and that is done only by way of E-proceedings.
27. It is submitted that in this case, the petitioner had all along
participated in the reassessment proceedings without raising any objection
regarding Jurisdiction. Therefore, as prescribed under Section 124(3) of the
Act, the petitioner is precluded from raising this objection after the assessment
order was passed. In this connection, a reference is made to the decision of the
Hon'ble Supreme Court in Deputy Commissioner of Income Tax
(Exemption) Vs. Kalinga Institute of Industrial Technology, (2023) 454
ITR 582 (SC).
28. As an answer to the above submission, the learned Senior Counsel
for the petitioner submits that the Faceless Assessment Officer lacks
jurisdiction to make addition. The learned Senior Counsel for the petitioner
would further submit that the reopening is with regard to capital gains and
addition is with regard to the sale of immovable property alone and legally,
there is no bar to consider any issue that comes to the notice of Assessing
Officer during the course of proceedings under Section 147 of the Income Tax
Act, 1961.
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29. The learned Senior Standing Counsel for the respondent would
further submit that the petitioner admits that there is exclusion of time limit
under the different provisions of Section 149 of the Income Tax Act, 1961 but
contends they are not applicable to Section 151 of the Act. It is submitted that
Section 151 of the Act provides the specified authority for the purposes of
Sections 148 and 148A of the Act. Therefore, time limit for issuances of Notice
under Section 148 of the Act is provided under Section 149 of the Act. It is
further submitted that the exclusion of time provided under the fifth and sixth
proviso are clearly attracted to this case.
30. The learned Senior Standing Counsel for the respondent would
further submit that Notice under Section 148A(b) of the Act was issued on
20.03.2022 giving time till 28.03.2022 and therefore the 9 days from
20.03.2022 to 28.03.2022 shall therefore be excluded under the fifth proviso to
Section 149 of the Act. It is therefore submitted that the notice under Section
148 of the Act following the order under Section 148A(d) has to be deemed to
be issued before 31.03.2022 by excluding these nine days. In this case, the
order under Section 148A(d) of the Act was passed on 05.04.2022 and notice
under Section 148 of the Act was issued on the following day i.e., on
06.04.2022.
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31. The learned Senior Standing Counsel for the respondents would
further submit that as far as the submission in respect to the addition made
under Section 69A of the Act is concerned, there are disputed questions of fact
and therefore the petitioner should be relegated to workout the remedy before
the Appellant Authority as the petitioner did not produce any proof for the
construction expenses and no documents were produced to show the same. It is
further submitted that the petitioner did not prove his claim regarding the cost
of improvement and therefore, the indexation cost of improvement claimed by
the petitioner towards computation of capital gain was disallowed and the
consideration/money received out of sale proceeds was brought to tax under
Section 69A of the Act, 1961.
32. The learned Senior Standing Counsel for the respondents has placed
reliance on the following decisions:-
i. Principal Commissioner of Income-tax (Central)-3,
New Delhi Vs. Jakhotia Plastics (P.) Ltd., [2018] 94
taxmann.com 89 (Delhi)
ii. N.Govindaraju Vs. Income-tax officer, [2015] 377
ITR 243 : [2015] 60 taxmann.com 333 (Karnataka)
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33. I have considered the arguments advanced by the learned Senior
Counsel for the petitioner and the learned counsel for the respondent. I have
also perused the documents filed in support of the present writ petition. I have
also considered the decisions of the courts relied upon by the learned Senior
Counsel for the petitioner and the learned Senior Standing Counsel for the
respondents.
34. Admittedly, the dispute pertains to the Assessment Year 2018-19.
The last date of the aforesaid Assessment Year was 31.03.2019. With effect
from 1.4.2021, the ecosphere of the assessment proceedings had undergone
tectonic changes.
35. The judgement of the Hon'ble Supreme Court in GKN Drive Shafts
(India) Ltd. Vs. Income Tax Officer & Ors. reported in (2003) 259 ITR 19
(SC) was statutory incorporated into the Income Tax Act, 1961 with effect from
the aforesaid date. Not only a notice but also speaking order had to be passed
before issuance of notice under Section 148 of the Income Tax Act, 1961 as
amended with effect from the aforesaid date. There are statutory restrictions in
place.
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36. As per the 1st proviso to Section 148 of theIncome Tax Act, 1961 as
amended with effect from 01.04.2021, no notice under aforesaid section shall
be issued unless there is information with the Assessing Officer which suggest
that the income chargeable to tax has escaped assessment in the case of
assessee for the relevant assessment year and the assessing officer has obtained
prior approval of the specified authority to issue such notice.
37. As per the 3rd proviso to Section 149 of the Income Tax Act, 1961,
for the purpose of computing the period of limitation, the time allowed to an
assessee to reply to the Show Cause Notice issued under Clause (b) of Section
148A of theIncome Tax Act, 1961 or the period during which the proceedings
under Section 148A of the Income Tax Act, 1961 has been stayed by an order
of injunction of any Court has to be excluded.
38. It is the case of the petitioner that the notice dated 06.04.2022 issued
under Section 148 of the Income Tax Act, 1961 was beyond the period of
limitation as the last date for issuance of the notice expired on 01.4.2022.
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39. However, if the 3rd proviso to Section 149 of the income tax is
applied, the time between 20.03.2022 being the date of issuance of show cause
notice issued under clause (b) of Section 148A of the Income Tax Act, 1961
and the time given for reply to the same till 28.3.2022 has to be excluded from
petitioner limitation.
40. Therefore, the limitation for issuance of notice under Section 148 of
the Income Tax Act, 1961 will stand extended till 08.04.2022. Therefore, the
argument that the notice under Section 148 of theIncome Tax Act, 1961 on
06.04.2022was beyond the period of limitation has to be rejected it has to be
held that the limitation did not expire on 31.03.2022 under Section 148 of the
Income Tax Act, 1961. Accordingly, the above objection of the petitioner
stands overruled.
41. In this case, the notice that was issued on 20.3.2022 under Section
148A (b) of theIncome Tax Act, 1961 clearly states that the said notice itself
was issued after obtaining prior approval of the Principal Commissioner of
Income Tax Madurai-1 which was appointed on 19.03.2022 vide Reference
No. 100000029738669.
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42. Similarly, the order that was passed on 05.04.2022 under Section
148A (d) of theIncome Tax Act, 1961, also states that the order was passed
with the approval of the the Principal Commissioner of Income Tax Madurai-1.
43. Similarly, the notice issued under Section 148 of the Income Tax Act,
1961 on 06.04.2022 also states that, it was issued after obtaining the prior
approval of thePrincipal Commissioner of Income Tax Madurai-1 vide
Reference No.100000029738669.
44. Since the notice has been issued within 3 years after excluding eight
days time given for giving a reply to notice dated 20.03.2022 issued under
Section 148A (b) of theIncome Tax Act, 1961,till 28.3.2022. Thus, eight days
has to be excluded for the purpose of computation of limitation under Section
149 of the Income Tax Act,1961 in terms of the 3rdprovisio to the said Section.
45. Therefore, respondents were not required to obtain sanction under
Section 151(ii) of the Income Tax Act, 1961 of the Principal Chief
Commissioner or the Principal Director-General or Chief Commissioner of
Director-General as the approval/sanction was obtained from the Principal
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Commissioner of Income Tax Madurai-1 on 19.3.2022 vide Reference No.
100000029738669 under Section 151(i) of theIncome Tax Act, 1961. It has to
be construed that the proceedings initiated underSection 148 of theIncome Tax
Act, 1961 on 06.04.2022 did not suffer from any irregularity.
46. In this case, both the notice dated 20.03.2022 issued under Section
148A(b) of the Income Tax Act, 1961 and the consequential speaking order
dated 05.04.2022 passed under Section 148A (d) of the Income Tax Act, 1961
were issued in time for issuance of a notice under Section 148 of the Income
Tax Act, 1961.
47. Under amended Section 148 of the Income Tax Act, 1961, as in force
with effect from 01.04.2021, a notice for the relevant assessment year had to be
either issued within 3 years from the end of the relevant assessment year or in
any other case within a period of 10 years from the end of the assessment year
where the Assessing Officer has in his possession books of account or other
documents or evidence which reveal that income chargeable to tax, represented
in the form of-
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(i)an asset;
(ii)expenditure in respect of a transaction or in relation to an
event or occasion; or
(iii)an entry or increase in the books of account,
which has escaped assessment amounts to or is likely to amount toRs.
50,00,000/-or more.
48. This a case where no regular returns was filed by the petitioner under
139(1) of the Income Tax Act, 1961 and thus notice under Section 148A of the
Income Tax Act, 1961 came to be issued after information was gathered .
49. Only in response to notice issued under Section 148 of theIncome
Tax Act, 1961 on 06.04.2022, a return of income was filed by the petitioner on
27.04.2022 pursuant to which the impugned assessment orders dated
03.01.2024 was passed by the 1st respondent under Section 147 and 144B of
the Income Tax Act, 1961. Therefore, there is no merits in the challenge to the
impugned assessment order dated 3.1.20 24 passed by the 1st respondent under
Section 147 and 144B of the Income Tax Act, 1961.
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50. The impugned assessment order dated 03.01.2024 passed by the 1st
respondent under Section 147 and 144B of the Income Tax Act, 1961 also
cannot be challenged as the procedure contemplated under 144B of theIncome
Tax Act, 1961 has been followed.
51. Therefore, this writ petition is liable to be dismissed. However,
liberty is given to the petitioner to challenge the impugned assessment order
dated 03.01.2024 passed by the 1st respondent under section 246A of the
Income Tax Act, 1961 before the Appellate Commissioner within a period of
30 days from the date of receipt of this order.
52. In case such an appeal is filed within such time, the appellate
Commissioner shall dispose the appeal on merits without further reference to
limitation in filing such appeal and without getting influenced by any of the
observation contained herein touching on merits of the case.
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53. These Writ Petitions stand dismissed with the above liberty. No costs.
Consequently, connected Writ Miscellaneous Petitions are closed.
03.01.2025
Index : Yes / No
Internet : Yes / No
Neutral Citation : Yes / No
Speaking Order / Non-Speaking Order
jas
To
1.The Assessment Unit,
Income Tax Department,
New Delhi.
2.The Income Tax Officer,
Ward 1(1),
Trichy,
Trichy Main Building, Williams Road,
Contonment,
Trichy – 620 015.
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C.SARAVANAN, J.
jen/jas
Pre-delivery order in
and
W.M.P.(MD)Nos.3537, 3538, 3539 of 2024
03.01.2025
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