Madras High Court
P.Sundararajan vs The Deputy Commissioner Of Income Tax on 10 July, 2025
TCA No.275 of 2016
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 10.07.2025
CORAM
THE HON'BLE MR.K.R.SHRIRAM, CHIEF JUSTICE
AND
THE HON'BLE MR.JUSTICE SUNDER MOHAN
TCA No.275 of 2016
P.Sundararajan : Appellant
versus
The Deputy Commissioner of Income Tax
Company Circle, Tiruppur : Respondent
Prayer: Appeal filed against the order of the Income Tax Appellate
Tribunal, Madras “D” Bench, Chennai, dated 25.06.2015 in
I.T.A.1666/Mds/2013.
For Appellant : Mr.I.Dinesh
for M/s.Philip George
For Respondent : Mr.V.Mahalingam
JUDGMENT
(Delivered by the Hon'ble Chief Justice)
Assessee, who is the appellant herein, is aggrieved with the order
pronounced on 25.06.2015, by the Income Tax Appellate Tribunal (ITAT)
with regard to AY 2006-07.
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2. Assessee is an individual, Director in a company by name
S.P.Apparels Ltd. Assessee had filed return of income on 13.03.2007 for AY
2006-07, by which assessee admitted total income of Rs.1,02,16,651/-. The
case was selected for scrutiny and an assessment order dated 22.04.2008
under Section 143(3) of the Income Tax Act, 1961 ('the Act') came to be
passed, wherein an addition of Rs.2,46,065/- under the head 'other
expenses' was made.
3. During FY 2005-06, pertaining to AY 2006-07, assessee had paid
interest on Rs.56,61,461/-. Assessee had also received interest income up to
30.11.2006, upon conversion of the capital account of assessee after
allotment of share had become unsecured loan. For this unsecured loan, no
interest was received from the company. Assessee was found to have
debited interest expenses to the tune of Rs.26,52,520/- in the profit and
loss account. All these were considered by the Assessing Officer and
assessment order dated 22.04.2008, as noted above, came to be passed.
4. Assessee thereafter received notice dated 25.03.2010 under
Section 148 of the Act, to which reply dated 22.04.2010 was filed.
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Thereafter, assessee's representative appeared before the Assessing Officer
and made oral submissions. Assessment order dated 23.12.2010 under
Section 143(3) read with Section 147 of the Act came to be passed, by which
assessee was called upon to pay additional tax plus interest. This was
challenged by the assessee by way of an appeal before the CIT (A). The
appeal came to be dismissed vide an order dated 25.06.2013. Aggrieved,
assessee preferred an appeal before the Income Tax Appellate Tribunal,
which came to be dismissed vide an order pronounced on 25.06.2015. It is
this order which is in challenge.
5. On 05.04.2016, the following substantial questions of law were
framed:
1. Whether on the facts and in the circumstances of the case,
the Income Tax Appellate Tribunal was right in law in
upholding the jurisdiction of the Assessing Officer in
reopening the assessment under Section 147 of the Income
Tax Act, 1961?
2. Whether on the facts and in the circumstances of the case,
the Income Tax Appellate Tribunal was right in law in
holding that there was no opinion formed by the Assessing
Officer while completing the original assessment under
Section 143(3) of the Income Tax Act, 1961 and there was
no change of opinion in reopening the assessment? And
3. Whether on the facts and in the circumstances of the case,
the Income Tax Appellate Tribunal was right in law in
upholding the dis-allowance of interest expenditure under
Section 36(1)(iii) of the Income Tax Act, 1961?”
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6. If Question Nos.1 and 2 are answered in favour of the assessee, we
need not go into the third question.
7. The reasons to believe has been reproduced by the Assistant
Commissioner of Income Tax in a letter dated 29.12.2014 addressed to
assessee and it reads as under:
“The assessee had shown sundry debtors of Rs.34.70
crores. He admitted interest received from M/s.S.P.Apparels of
Rs.1,61,93,186/- vide his letter dated nil filed in this office on
22.04.2008, the assessee explained that he was deriving income as
interest on capital from M/s.S.P.Apparels and interest from bank
only. Further, vide letter dated 22.04.2008 the assessee explained
that his sundry debtors include Rs.24,52,61,020/- from
M/s.S.P.Apparels Ltd which is a closely held company.
In the balance sheet furnished as on 31.03.2006, the
assessee has not mentioned anything about his assets or liabilities
with the firm in which he is a partner. As already mentioned
sundry debtors mainly consist of the investments with
M/s.S.P.Apparels Ltd.
Assessee's admitted income includes only interest from
bank and M/s.S.P.Apparels apart from the share of profit from the
said firm. He has claimed interest paid of Rs.56,61,461/-. There is
no detail available on record to indicate that the loans borrowed
were utilized to make investment with M/s.S.P.Apparels (firm).
Only the contrary, all the assets shown are not related to the
purpose of any business activity. It is true that the assessee has
made investments to the tune of Rs.12 crores in shares. But, he has
not admitted any dividend income from such shares. Hence, the
claim of interest paid is not related to investments in any business
activity or in any income generating assets or activity. Thus, in the
return furnished and as per the enclosures, the assessee has
claimed an item of expenditure which is not allowable under law
and thus the assessee's income has been made the subject of
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excessive relief under the Act as provided in sub-clause © of
explanation 2 to Sec.147. Hence, I have reason to believe that
income chargeable to tax has escaped assessment.”
8. The assessee's stand, apart from on merits, is that the reopening
itself was not permissible. Shri Dinesh submitted that even though the
reopening was within four years from the end of the relevant assessment
year, the reopening is purely based on change of opinion and all materials
available for assessment had already been available with the Assessing
Officer before he passed the original assessment order.
9. Relying on CIT vs. Kelvinator of India Ltd1, Shri Dinesh
submitted that the reasons must have a live link with the formation of the
belief. Even though the Assessing Officer has power to reopen, there has to
be tangible material to come to the conclusion that there is escapement of
income from assessment. Counsel submitted that there has to be some new
ground, otherwise, it would vest arbitrary powers in the Assessing Officer,
who, in the garb of reopening, will end up reviewing the assessment order.
1 [2010] 320 ITR 561
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10. Counsel also relied on a judgment of the Apex Court in Calcutta
Discount Co.Ltd vs. ITO2, to submit that though there can be no doubt
that the duty of disclosing all the primary facts relevant to the decision of
the question before the assessing authority lies on the assessee, there is no
duty on the assessee to disclose further facts, which on due diligence, the
Income Tax Officer might have discovered. He further submitted that the
duty, however, does not extend beyond the full and truthful disclosure of all
primary facts. Once all the primary facts are before the assessing authority,
he requires no further assistance by way of disclosure. It is for the
Assessing Officer to decide what inferences of facts can reasonably be
drawn and what legal inferences have ultimately to be drawn.
11. Counsel submitted that during the course of original assessment
proceedings on the same issue which formed the basis for reason to believe,
queries were raised and assessee, vide a letter dated 22.04.2008, provided
further particulars. Counsel submitted that the details of the debtors, as
also expenses incurred towards interest income were given in the said
letter and it clearly says that interest paid was Rs.56,61,461/- apart from
2 [1961] 41 ITR 191 (SC)
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other expenses. These details also find a mention in the income and
expenditure account filed along with the returns.
12. Shri Dinesh submitted that after considering these further
particulars, the assessment order came to be passed accepting the returns,
except adding a sum of Rs.2,46,065/- claimed as other expenses other than
interest payment which was disallowed.
13. Counsel also submitted that once a query is raised during the
assessment proceedings, and the assessee has replied to it, it follows that
the query raised was a subject of consideration of the Assessing Officer,
while completing the assessment. It is not necessary that an assessment
order should contain reference and/or discussion to disclose its satisfaction
in respect of the query raised.
14. Shri Mahalingam's submissions were more on merits. Of course,
he also submitted that the claim of interest paid is not reflected as
investment in any business activities or in any income generating expenses
and hence, there was excessive relief claimed by the assessee in the form of
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interest payments. The original assessment order does not reflect any
application of mind by the Assessing Officer to the claim of interest
payment. Mere production before the Assessing Officer of account books or
other evidence from which material facts could with due diligence has been
discovered by the Assessing Officer, will not necessarily amount to
disclosure within the meaning of the Section 147 of the Act.
15. Shri Mahalingam also submitted that had the assessee disclosed
the interest payment bifurcation to the Assessing Officer at the time of the
original assessment, then it could have been said that the assessee has done
his duty and it is for the Assessing Officer to draw any inference on the
facts placed before him. But the assessee has not done so and therefore,
there was a failure on the part of the assessee to disclose the fact that the
assessee made investment in firm/companies and had not derived any
benefit though assessee incurred heavy interest expenditure and it was this
failure on the part of the assessee that was the reason to reopen the original
assessment.
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16. In our view, the duty of an assessee does not extend beyond the
full and truthful disclosure of all primary facts. Once all the primary facts
are before the assessing authority, he requires no further assistance by way
of disclosure. It is for him to decide what inferences of facts can be
reasonably drawn and what legal inferences have ultimately to be drawn. It
is not for somebody else – far less the assessee – to tell the Assessing
Officer what inferences, whether of facts or law, should be drawn. The Apex
Court in Calcutta Discount Co. Ltd (supra), observed, “Indeed, when it is
remembered that people often differ as regards what inferences should be
drawn from given facts, it will be meaningless to demand that the
assessee must disclose what inferences - whether of facts or law - he
would draw from the primary facts. If from primary facts more
inferences than one could be drawn, it would not be possible to say that
the assessee should have drawn any particular inference and
communicated it to the assessing authority. How could an assessee be
charged with failure to communicate an inference, which he might or
might not have drawn. The explanation to Section 147 has nothing to do
with "inferences" and deals only with the question whether primary
material facts not disclosed could still be said to be constructively
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disclosed on the ground that with due diligence the Income-tax Officer
could have discovered them from the facts actually disclosed. The
Explanation has not the effect of enlarging the section, by casting a duty
on the assessee to disclose "inferences" to draw the proper inferences
being the duty imposed on the Income Tax Officer”.
17. Here is a case, where, in the income and expenditure account
filed along with the return of income, assessee had mentioned about the
interest paid of Rs.56,61,461/-. During the course of assessment
proceedings, query was raised and assessee vide a letter dated 22.04.2008,
again gave the particulars. The Assessing Officer did not consider it
necessary to ask for further details like indication that the loans borrowed
were utilised to make investments in the firm. As held in Calcutta Discount
Ltd (supra), which was followed by a Division Bench of the Bombay High
Court in Ananta Landmark (P) Ltd vs. Deputy Commissioner of
Income Tax, Central Circle 5(3), Mumbai3, while the duty of the
assessee is to disclose fully and truly all primary relevant facts, it does not
extend beyond that.
3 [2021] (131) taxmann.com 52 (Bombay)
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18. Paragraph 13 of Ananta Landmark (P) Ltd (supra) reads as
under:
“13. As regards ground nos.(iv) to (vi) that the disclosure of
material facts with respect to the setting off of the interest expenses
under Section 57 of the Act might be full but it cannot be considered
as true and hence, it is failure on the part of the assessee, mere
production of books of accounts or other documents are not enough
in view of explanation 1 to Section 147 etc., these can be dealt with
together. The Apex Court in Calcutta Discount Co. Ltd. vs. Income
Tax Officer [1961] 41 ITR 191, relied upon by Mr. Pardiwalla, has
held that there can be no doubt that the duty of disclosing all the
primary facts relevant to the decision of the question before the
assessing authority lies on the assessee. To meet a possible
contention that when some account books or other evidence has
been produced, there is no duty on the assessee to disclose further
facts, which on due diligence, the Income Tax Officer might have
discovered, the Legislature has put in the Explanation to Section 34
(1). The duty, however, does not extend beyond the full and truthful
disclosure of all c primary facts. Once all the primary facts are
before the assessing authority, he requires no further assistance by
way of disclosure. It is for him to decide what inferences of facts can
be reasonably drawn and what legal inferences have ultimately to be
drawn. It is not for somebody else far less the assessee to tell the
assessing authority what inferences, whether of facts or law, should
be drawn. Indeed, when it is remembered that people often differ as
regards what inferences should be drawn from given facts, it will be
meaningless to demand that the assessee must disclose what
inferences - whether of facts or law - he would draw from the
primary facts. If from primary facts more inferences than one could
be drawn, it would not be possible to say that the assessee should
have drawn any particular inference and communicated it to the
assessing authority. How could an assessee be charged with failure
to communicate an inference, which he might or might not have
drawn? It may be pointed out that the Explanation to the sub-
section has nothing to do with "inferences" and deals only with the
question whether primary material facts not disclosed could still be
said to be constructively disclosed on the ground that with due
diligence the Income-tax Officer could have discovered them from
the facts actually disclosed. The Explanation has not the effect of
enlarging the section, by casting a duty on the assessee to disclose
"inferences" to draw the proper inferences being the duty imposed
on the Income Tax Officer. Therefore, it can be concluded that while
the duty of the assessee is to disclose fully and truly all primary
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relevant facts, it does not extend beyond this.
The relevant portion of Calcutta Discount Co. Ltd. (Supra)
reads as under :
Before we proceed to consider the materials on
record to see whether the appellant has succeeded ,in
showing that the Income-tax Officer could have no
reason, on the materials before him, to believe that
there had been any omission to disclose material facts,
as mentioned in the section, it is necessary to examine
the precise scope of disclosure which the section
demands. The words used are " omission or failure to
disclose fully and truly all material facts necessary for
his assessment for that year ". It postulates a duty on
every assessee to disclose fully and truly all material
facts necessary for his assessment. What facts are
material, and necessary for assessment will differ from
case to case. In every assessment proceeding, the
assessing authority will, for the purpose of computing
or determining the proper tax due from an assessee,
require to know all the facts which help him in coming
to the correct conclusion. From the primary facts in his
Possession, whether on disclosure by the assessee, or
discovered by him on the basis of the facts disclosed, or
otherwise-the assessing authority has to draw
inferences as regards certain other facts; and ultimately,
from the primary facts and the further facts inferred
from them, the authority has to draw the proper legal
inferences, and ascertain on a correct interpretation of
the taxing enactment, the proper tax leviable. Thus,
when a question arises whether certain income received
by an assessee is capital receipt, or revenue receipt, the
assessing authority has to find out what primary facts
have been proved, what other facts can be inferred from
them, and taking all these together, to decide what the
legal inference should be.
There can be no doubt that the duty of
disclosing all the primary facts relevant to the decision
of the question before the assessing authority lies on the
assessee. To meet a possible contention that when some
account books or other evidence has been produced,
there is no duty on the assessee to disclose further facts,
which on due diligence, the Income- tax Officer might
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have discovered, the Legislature has put in the
Explanation, which has been set out above., In view of
the Explanation, it will not be open to the assessee to
say, for example-" I have produced the account books
and the documents: You, the Assessing Officer examine
them, and find out the facts necessary for your purpose:
My duty is done with disclosing these account-books
and the documents". His omission to bring to the
assessing authority's attention these particular items in
the account books, or the particular portions of the
documents, which are relevant, amount to " omission to
disclose fully and truly all material facts necessary for
his assessment." Nor will he be able to contend
successfully that by disclosing certain evidence, he
should be deemed to have disclosed other evidence,
which might have been discovered by the assessing
authority if he had pursued investigation on the basis of
what has been disclosed. The Explanation to the
section, gives a quietus to all such contentions; and the
position remains that so far as primary facts are
concerned, it is the assessee's duty to disclose all of
them-including particular entries in account books,
particular portions of documents and documents, and
other evidence, which could have been discovered by
the assessing authority, from the documents and other
evidence disclosed.
Does the duty however extend beyond the full
and truthful disclosure of all primary facts ? In our
opinion, the answer to this question must be in the
negative. Once all the primary facts are before the
assessing authority, he requires no further assistance by
way of disclosure. It is for him to decide what inferences
of facts can be reasonably drawn and what legal
inferences have ultimately to be drawn. It is not for
somebody else-far less the assessee--to tell the assessing
authority what inferences-whether of facts or law
should be drawn. Indeed, when it is remembered that
people often differ as regards what inferences should be
drawn from given facts, it will be meaningless to
demand that the assessee must disclose what
inferences-whether of facts or law-he would draw from
the primary facts.
If from primary facts more inferences than one
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could be drawn, it would not be possible to say that the
assessee should have drawn any particular inference
and communicated it to the assessing authority. How
could an assessee be charged with failure to
communicate an inference, which he might or might
not have drawn?
It may be pointed out that the Explanation to
the sub- section has nothing to do with " inferences "
and deals only with the question whether primary
material facts not disclosed could still be said to be
constructively disclosed on the ground that with due
diligence the Income-tax Officer could have discovered
them from the facts actually disclosed. The Explanation
has not the effect of enlarging the section, by casting a
duty on the assessee to disclose " inferences "-to draw
the proper inferences being the duty imposed on the
Income-fax Officer.
We have therefore come to the Conclusion that
while the duty of the assessee is to disclose fully and
truly all primary relevant facts, it does not extend
beyond this.
The position, therefore, is that if there were in
fact some reasonable grounds for thinking that there
had been any non- disclosure as regards any primary
fact, which could have a material bearing on the
question of "under assessments that would be sufficient
to give jurisdiction to the Income-tax Officer to issue
the notice under Section 34. Whether these grounds
were adequate or not for arriving at the conclusion that
there was a non disclosure of material facts would not
be open for the court's investigation. In other words, all
that is necessary to give this special jurisdiction is that
the Income- tax officer had when he assumed
jurisdiction some prima facie grounds for thinking that
there had been some non- disclosure of material facts.
.................
Both the conditions, (i) the Income-tax Officer
having reason to believe that there has been under
assessment and (ii) his having reason to believe that
such under assessment has resulted from nondisclosure
of material facts, must co-exist before the Income-tax
Officer has jurisdiction to start proceedings after the
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expiry of 4 years. The argument that the Court ought
not to investigate the existence of one of these
conditions, viz., that the Income-tax Officer has reason
to believe that under assessment has resulted from non-
disclosure of material facts, cannot therefore be
accepted.”
(emphasis supplied)
19. Therefore, it cannot be stated that the assessee failed in its
primary duty of disclosing relevant facts.
20. Moreover, as held by the Bombay High Court in Aroni
Commercials Ltd. vs. Deputy Commissioner of Income Tax 2(1)4,
once a query is raised during the assessment proceedings and the assessee
has replied to it, it follows that the query raised was a subject of
consideration of the Assessing Officer while completing the assessment. It
is not necessary that an assessment order should contain reference and/or
discussion to disclose its satisfaction in respect of the query raised. As held
in Aroni Commercials (supra), “the manner in which an assessment order
is to be drafted is the sole domain of the Assessing Officer and it is not
open to an assessee to insist that the assessment order must record all the
questions raised and the satisfaction in respect thereof of the Assessing
Officer. The only requirement is that the Assessing Officer ought to have
4 [2014] 44 taxmann.com 304 (Bombay)
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considered the objection now raised in the grounds for issuing notice
under Section 148 of the Act, during the original assessment proceedings”.
Paragraph 14 of the order reads as under:
“14) We find that during the assessment proceedings the
petitioner had by a letter dated 9 July 2010 pointed out that they
were engaged in the business of financing trading and investment
in shares and securities. Further, by a letter dated 8 September
2010 during the course of assessment proceedings on a specific
query made by the Assessing Officer, the petitioner has disclosed
in detail as to why its profit on sale of investments should not be
taxed as business profits but charged to tax under the head capital
gain. In support of its contention the petitioner had also relied
upon CBDT Circular No.4/2007 dated 15 June 2007. (The reasons
for reopening furnished by the Assessing Officer also places
reliance upon CBDT Circular dated 15 June 2007). It would
therefore, be noticed that the very ground on which the notice
dated 28 March 2013 seeks to reopen the assessment for
assessment year 2008-09 was considered by the Assessing Officer
while originally passing assessment order dated 12 October 2010.
This by itself demonstrates the fact that notice dated 28 March
2013 under Section 148 of the Act seeking to reopen assessment for
A.Y. 2008-09 is based on mere change of opinion. However,
according to Mr. Chhotaray, learned Counsel for the revenue the
aforesaid issue now raised has not been considered earlier as the
same is not referred to in the assessment order dated 12 October
2010 passed for A.Y. 2008-09. We are of the view that once a
query is raised during the assessment proceedings and the
assessee has replied to it, it follows that the query raised was a
subject of consideration of the Assessing Officer while completing
the assessment. It is not necessary that an assessment order
should contain reference and/or discussion to disclose its
satisfaction in respect of the query raised. If an Assessing Officer
has to record the consideration bestowed by him on all issues
raised by him during the assessment proceeding even where he is
satisfied then it would be impossible for the Assessing Officer to
complete all the assessments which are required to be scrutinized
by him under Section 143(3) of the Act. Moreover, one must not
forget that the manner in which an assessment order is to be
drafted is the sole domain of the Assessing Officer and it is not
open to an assessee to insist that the assessment order must record
all the questions raised and the satisfaction in respect thereof of
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the Assessing Officer. The only requirement is that the Assessing
Officer ought to have considered the objection now raised in the
grounds for issuing notice under Section 148 of the Act, during the
original assessment proceedings. There can be no doubt in the
present facts as evidenced by a letter dated 8 September 2012 the
very issue of taxability of sale of shares under the head capital
gain or the head profits and gains from business was a subject
matter of consideration by the Assessing Officer during the
original assessment proceedings leading to an order dated 12
October 2010. It would therefore, follow that the reopening of the
assessment by impugned notice dated 28 March 2013 is merely on
the basis of change of opinion of the Assessing Officer from that
held earlier during the course of assessment proceeding leading to
the order dated 12 October 2010. This change of opinion does not
constitute justification and/or reasons to believe that income
chargeable to tax has escaped assessment.”
21. The fact that during the original assessment proceedings,
assessee had addressed a communication dated 22.04.2008 on the same
grounds, based on which this notice under Section 148 of the Act has been
issued, itself confirms the fact that this issue was a subject of consideration
of the Assessing Officer while completing the original assessment.
22. Having considered the reasons, we would opine that the
reopening of the assessment was merely on the basis of change of opinion
of the Assessing Officer from that, as held earlier during the course of
assessment proceedings, leading to the assessment order dated
22.04.2008. This change of opinion does not constitute justification and/or
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reasons to believe that income chargeable to tax has escaped assessment.
23. In the circumstances, in our view, Question Nos.1 and 2 have to
be answered in favour of the assessee and it is so answered. In view of our
answer to Question Nos.1 and 2, in our opinion, Question No.3 need not be
answered.
24. Appeal stands disposed of. There shall be no order as to costs.
(K.R.SHRIRAM, CJ.) (SUNDER MOHAN, J.)
10.07.2025
Index : Yes/No
Neutral Citation : Yes/No
tar
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To
1.The Deputy Commissioner of Income Tax
Company Circle, Tiruppur
2.The Income Tax Appellate Tribunal,
Madras “D” Bench, Chennai
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THE HON'BLE CHIEF JUSTICE
AND
SUNDER MOHAN, J.
(tar)
10.07.2025
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