Madras High Court
M/S.Ponni Sugars (Erode) Ltd vs The Deputy Commissioner Of Income Tax on 18 March, 2025
Author: Mohammed Shaffiq
Bench: Mohammed Shaffiq
WP No.30083 of 2019
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 18.03.2025
CORAM:
THE HONOURABLE MR.JUSTICE MOHAMMED SHAFFIQ
WP. No.30083 of 2019
and
WMP No.30023 of 2019
M/s.Ponni Sugars (Erode) Ltd.,
Represented by its Deputy General Manager Accounts,
Mr.G.Lakshmi Narayanan ... Petitioner
versus
The Deputy Commissioner of Income Tax
Corporate Circle 5(2)
4th Floor, Aayakkar Bhawan,
121, Mahatma Gandhi Road,
Nungambakkam,
Chennai -600 034. ... Respondent
PRAYER: Writ Petition filed under Article 226 of the Constitution of India,
for the issuance of a writ of Certiorari, calling for the records in
C.C.5(2)/2019-20 dated 04.10.2019 on the file of the respondent relating to
the assessment year 2012-13 and quash the same and pass orders.
For the Petitioner :Mr.G.Baskar
For the Respondent :Mr.V.Mahalingam
Senior Standing Counsel
1/23
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WP No.30083 of 2019
ORDER
The present writ petition is filed challenging the impugned order
dated 04.10.2019 whereby, the petitioner's objection against issuance of
notice under Section 148 of the Income Tax Act, 1961 (in short, 'the Act')
was rejected.
2. Petitioner is a company registered under the Companies Act, 1956 .
Petitioner carries on business of manufacture and sale of sugar and its by-
products. For the assessment year 2013-14, petitioner filed its return and
paid appropriate taxes. Petitioner's return was taken up for scrutiny by
issuance of notice dated 06.08.2013 under Section 143(2) of the Act.
During the course of scrutiny, a number of issues inter alia including the
following were examined viz.,
a) Dividend Distribution Tax;
b) Performance Incentive; and
c) Power Evacuation Arrangement Expenses
3. After the scrutiny assessment order dated 18.03.2015 was passed, a
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notice came to be issued dated 20.03.2019 under Section 148 of the Act,
wherein the following three issues were raised viz.,
i) Delay in payment of dividend distribution tax;
ii) Allowability of performance incentive as an expenditure; and
iii) Allowability of power evacuation charges as expenditure.
4. The petitioner sought reasons for reopening assessment. Reasons
were furnished by the Assessing Officer vide communication dated
10.05.2019 and the same reads as under:
"With reference to the above, the reasons as recorded by the
Assessing Officer for reopening the assessment u/s 147 of the
Income Tax Act, 1961 for the A.Y.2012-13 is furnished as under:
1.In the income computation statement assessee claimed
deduction of Rs.15,17,878/- with the narration "Performance
incentive paid relating to previous year but not debited to P&L A/c".
However, it had qualified this incentive as bonus payable to staff for
their performance in the F.Y.2011-12 and hence claimed the same as
deduction. It is seen from the details that bonus/incentives was
declared only on 01/06/2012 i.e. after close of the accounting year.
This shows that the liability to pay such bonus accrued only after
close of the accounting year though it pertains to the accounting
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year. Since payment of bonus/incentive is a contractual liability, it
crystallizes only when it is settled or adjudicated. Therefore, such
liability had not accrued in the assessee's case during the year and
hence is not allowed as a legitimate expenditure. In view of the
same, the excess deduction claimed by the assessee to the tune of
Rs.15,17,878/- ought to come under the ambit of taxation.
The assessee company declared dividend on 27/05/2011 in the
Annual General Meeting. The tax on dividend was paid on
27.05.2011 Rs.27,89,756/-. As per the provisions u/s 1150 the tax on
the dividend had to be paid within 14 days of deduction, distribution
or payment of dividend, by whichever is earliest. In this case the
same had to be credited to Government Account by 10/06/2011.
Since the tax was paid belatedly i.e. 27/07/2011 the assessee had
failed to remit interest u/s 115P amounting Rs.55795/- being 2% of
the dividend tax.
The assessee had claimed Rs.2,21,30,153/- exceptional item
towards power evacuation arrangement expenses. It is seen that this
expenditure would benefit the assessee in its long run of the business
and therefore cannot fit into the scheme of revenue expenditure. The
same is a capital expenditure and accordingly is not an expenditure
which can be allowed to be deducted from its income. It is further
noted that the assessee has not commenced the business and not
brought any revenue i.e. the sale of power in its P & L, where it has
credited only the sale of sugar bagasse, molasses, scrap and sugar.
Since the entire expenditure of Rs.2.12 Crores relates to the sale of
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power and no sales was done, thus on matching concept expenditure
has to be disallowed.
Based on the discussion above, I have reason to believe that
income over and above Rs.1 lakh has excaped assessment and that it
is a fit case for issuing notice u/s 148 of the Income Tax Act."
You are requested to file objections, if any, to the reopening
proceedings latest by 17/05/2019."
5. In response, the petitioner submitted its objection dated
20.05.2019, inter alia highlighting that the above issues were the subject
matter of scrutiny assessment. The petitioner made a full and true
disclosure of all the material particulars called for by issue of notice under
Section 142(1) of the Act during scrutiny assessment proceedings. The
relevant portion of the reply reads as under:
“13. It is submitted that the details in respect performance
incentive pay relating to previous year but not debited to P & L Rs.
15,17,878 was filed during the course of hearing on 20.02.2015. The
note on the same gives full details and the basis on which the
deduction is allowable. The note is self-explanatory and therefore,
the deduction allowed in the original assessment proceedings is in
order and need not be disturbed.
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14. With respect to the dividend and the tax thereon, it is
submitted that dividend declaration and the consequent payment of
dividend distribution tax within the due date are not part of
assessment of income or escapement of income. It is also submitted
that while the accounts are approved by the Board of Directors on
27.05.2011and is subject to the approval of the shareholders in a
General Body Meeting. The power to approve the dividend vests
with the General Body and accordingly, the same was approved by
the Members at the General Body Meeting held on 15.07.2011.
These details are available inthe Annual Report for 2010-11 which
was submitted on 21.04.2014 in response to the notice under Section
142(1) dated 15.04.2014. The dividend was approved and declared
on 15.07.2011 and the tax on dividend under Section 115(0) has
been paid on 27.07.2011 i.e. within 15 days from the date of
declaration of dividend. Thus, there is no delay as assumed by you.
15. In respect of the power evacuation expenses, it was
disclosed as an exceptional item in the Profit and Loss Account. A
detailed note was filed on 02.03.2015 along with various decisions
of High Court and the amendments to the Tamil Nadu Electricity
Regulatory Commission. After examining those details, the AO was
satisfied and after forming an opinion passed the order allowing
deduction.
16. It may be seen from the facts on record and brought to
your attention that in respect of the 3 items which are the reasons for
issuing the notice under Section 148, the details were called for by
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the AO specifically, full and particulars of details were furnished,
examined by the AO and after forming an opinion, the order under
Section 143(3) was passed.
17. No new material had come to your possession justifying
re-opening of the assessment. The self same materials which were
placed by us in the course of the assessment proceedings finds a
mention in the reasons recorded. It is, therefore, submitted that the
present proceedings are merely on the basis of 'change of opinion'
and re-assessment proceeding based on change of opinion is not
permissible. We rely on the decision of the Supreme Court in CIT Vs.
Kelvinator of India Limited 320 ITR 561.Therefore, the re-
assessment proceedings are not valid and lack jurisdiction.
18. The proviso to Section 147 reads as under.
"Provided that where an assessment under sub-section (3) of
Section 143 of this Section has been made for the relevant
assessment year, no action shall be taken under this Section after the
expiry of four years from the end of the relevant assessment year,
unless any income chargeable to tax has escaped assessment for
such assessment year by reason of the failure on the part of the
assessee to make a return under Section 139 or in response to a
notice issued under sub-section (1) of Section 142 or Section 148 or
to disclose fully and truly all material facts necessary for his
assessment, for that assessment year."
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19. In our case we had filed our return under Section 139(1)
before the due date disclosing fully and truly all the materials
necessary for assessment.
20. We had also filed full and true particulars of the details
called for by issue of notice under Section 142(1) during assessment
proceedings. The assessment has been completed under Section
143(3) by order dated 18.03.2015. Four years from the end of the
relevant assessment year ended by 31.03.2017. Even in the reasons
recorded, there is no averment or allegation about our failure to
disclose any material required for completion of assessment. The
issue of notice dated 29.03.2019 is after the time said in the proviso
to Section 147 and therefore time barred.
21. It is, therefore, prayed that the proposed proceedings u/s
148 may please be dropped as the same lacks jurisdiction as well as
barred by time limitation.”
5.1. However, the objections were rejected vide impugned order dated
04.10.2019, by stating that reasons warranting re-assessment have been
recorded after taking into account all relevant factors. The relevant portion
is extracted hereunder:
“3.1. Firstly, the bonus/incentive was declared after the
closure of the accounting year F.Y. 2011-12 (i.e.) 01.06.2012 thereby,
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the liability has accrued only after the closure of accounting year
though it pertains to the accounting year. Moreover, bonus /
incentive are a contractual liability, it crystallizes only when it is
settled or adjudicated. Hence, your objection is not acceptable.
3.2. The second reason recorded for reassessment
proceedings pertains to late payment of tax on the dividend
declared/ distributed as per the provisions u/s 1150 and the
corresponding interest charges u/s 115P as per the submissions
made by the assessee and materials available on record. Thus, there
is no assumption in this regard and the reasons recorded for
reopening the assessment is based on the facts on the records
available.
3.3. With respect to power evacuation expenses, whether the
sufficiency/correctness of the detailed note submitted by the assessee
is not a thing to be considered at this stage. During the course of
reassessment proceedings you will be afforded adequate opportunity
to explain your case and the resultant order will be passed based on
an objective appraisal of the evidences available.
3.4. Further, it has been stated in the objections that the
assessment proceedings are based merely on the change of opinion
and that lacks jurisdiction as well as barred by time limitation. In
this aspect, it is clarified that reasons have been recorded only after
taking into account all the relevant factors and information.
4. To conclude, I am emphasizing the fact that reopening in
the case of the assessee is valid in light of the facts and established
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law. The procedural requirements such as proper recording of
reasons, service of notices and Forwarding of reasons have been
met. Having said this, the matters raised by the assessee having been
dealt in the elaborate manner.”
6. The challenge to the impugned proceedings is on the premise that it
is without jurisdiction primarily for two reasons viz.,
a) Re-assessment is made on the basis of mere change of opinion.
b) No finding that there was a failure on the part of the assessee to
fully and truly disclose material particulars.
7. This Court posed two questions to the learned counsel for the
Respondent viz.,
a) Whether the above three issues were raised during the course of
scrutiny assessment and thus re assessment proceeding is only a change of
opinion which may not constitute a valid ground for exercise of power of re
assessment.
b) Is there any finding either in the notice or in the impugned order
under Section 148 A (d) rejecting the objections, of failure on the part of the
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assessee to fully and truly disclose the material particulars which is a
condition precedent to invoke power of re-assessment inasmuch as the re
assessment proceedings is admittedly initiated after expiry of 4 years from
the end of the relevant assessment year.
8. In response the learned Senior Standing Counsel does not respond
nor contest the above issues except to state that the issue on jurisdiction can
always be adjudicated by the assessing officer and thus no interference is
warranted under Article 226 of Constitution at this stage.
9. This Court finds from perusal of records that the above three
issues raised in the re assessment viz., a) Delay in payment of dividend
distribution tax, b) Performance Incentive and c) Power Evacuation
arrangement expenses, was considered even while framing the scrutiny
assessment, as would be evident from the following:
a) Dividend Distribution Tax:
9.1. The respondent issued a notice under sub Section (1) to Section
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142 of the Act wherein the issue of Divident Distribution Tax was raised,
evident from the following:
“7. Details of investent made by the cmpany and expenditures
inurred directly in relation to such investments. Details of income
(dividend) earned from the investment.
8. Copy of the Wealth tax Return. If not applicable
substatiate the same.”
9.2. In response the petitioner vide letter dated 27.10.2014 had
submitted the following :
ANNEXURE VII
PONNI SUGARS ERODE LIMITED
PREVIOUS YEAR ENDED 31.03.2012
INCOME TAX ASSESSMENT 2012-2013
Details for Dividend Distribution Tax paid during the year
FY 2011-12
Amount(Rs)
Share Capital as on 31.03.2011 8598418
Rate of Dividend 20%
Dividend @ 20% 17196836
Dividend Distribution Tax @15% 2579525
Surcharge @5.0% 128976
Edu. Cess & S&H Cess @3% 81255
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ANNEXURE VII
Total Dividend Distribution Tax Rs. 2789756
9.3. Importantly, the 16th Annual Report and Director's Report which
was submitted contains the following:
“NOTICE OF ANNUAL GENERAL MEETING
...
2. Dividend declaration
To declare dividend on Equity Shares.”
.....
“DIRECTOR' REPORT
....
Dividend
Your Directors recommend a dividend of Rs.2.50 per Equity Share
of Rs.10 each for the Financial year ended 31st March 2012.”
.....
“Dividend for 2011-12
(a) Dividend entitlement
Dividend, if declared at the annual General Meeting, will be paid
on 6th August 2012 to the members whole names appear on the Register of
Members on 20th July 2012 or to their mandates. In respect of shares held
in electronic form, dividend will be paid to the beneficial owners of shares
recorded with the depositories as of 20th July 2012 as per details to be
furnished by NSDL / CDSL for the purpose.”
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b) Performance Incentive:
9.4. During the course of the scrutiny assessment, , the chartered
accountant of the petitioner vide his letter dated 20.02.2015, stated that
Performance Incentive had been reduced from Income Computation as
could be seen from the following:
"A sum of Rs.1517878/- has been reduced from income
computation under Performance incentive paid relating to the
previous year but not debited to profit and loss account- please
clarify why this should be allowed as an expenditure when it is not
debited in the profit and loss account especially when you are
following mercantile system of accounting."
9.5. A circular dated 01.06.2012 has also been kept in the typed set of
papers, which indicates that the performance incentive was sanctioned for
the financial year 2011-12. The above documents was sought to be relied
upon by the petitioner in support of their contention that performance
incentive was also considered during the course of scrutiny assessment,
which this Court finds merit.
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c) Power Evacuation Arrangement Expenses:
9.6. In response to a notice dated 15.10.2014, the Chartered
Accountant of the petitioner submitted a letter dated 02.03.2015, which
contained a detailed report on Power Evacuation Arrangement expenses
running to about three pages. The relevant portion of the letter wherein
submission of the detailed note on Power Evacuation Arrangement
expenses is referred is extracted hereunder:
"Under the instructions from the above referred Assessee and
further to the hearing attended by us, we are pleased to file the
following as required by you in the enclosed annexure.
1. Detailed note on Power evacuation arrangement expenses"
10. From the above it is clear that the above three issues were raised
during the course of scrutiny assessment, the impugned proceedings of re-
assessment in the absence of new and tangible material would only
constitute change of opinion and thus without jurisdiction. Importantly, as
stated above the respondent were not in a position to place before this Court
any new material for a valid exercise of power of re assessment under
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Section 147 read with 148 of the Act. It is trite law that power of re-
assesment cannot be exercised on the basis of mere change of opinion. In
this regard it may be relevant to refer to the judgment of the Supreme Court
in Mobis India Ltd. v. Dy. CIT, reported in (2023) 450 ITR 60, wherein it
was held as under:
“12. It is trite law that the power to assess the escaped
income under section 147 though stands broadened/expanded over
the years through periodical amendments, one feature which has
remained constant/unchanged and prevailed during the relevant
assessment year is the limitation on the power to reassess on a mere
change of opinion. In this regard, it may be relevant to refer to the
judgment of the Supreme Court in CIT v. Kelvinator of India Ltd.
reported in [2010] 320 ITR 561 (SC), wherein, after setting out the
legislative history and capturing the changes brought out
periodically to section 147 of the Income-tax Act, 1961, found that
the powers are much wider under section 147 in view of the
amendments. However, it was made clear that the power of
reassessment is not meant to be a power of review nor can
assessments be reopened on mere change of opinion lest section 147
become vulnerable to challenge as conferring arbitrary power to the
Assessing Officer.”
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10.1. The above view of the Supreme Court has been reiterated
repeatedly and it has been held consistently that reassessment cannot be
made on mere change of opinion. In this regard it may be relevant to refer to
the judgment of the Supreme Court in ITO v. Techspan India (P.) Ltd.,
reported in (2018) 6 SCC 685, wherein it was held as under:
“19. ..... Hence, initiation of the reassessment proceedings
under section 147 by issuing a notice under section 148 merely
because of the fact that now the Assessing Officer is of the view that
the deduction under section 10A was allowed in excess, was based
on nothing but a change of opinion on the same facts and
circumstances which were already in his knowledge even during the
original assessment proceedings."
10.2. It may also be relevant to note that once a query is raised during
the assessment proceedings and an assessee submits its reply/responds to it
and assessments are completed thereafter. It follows that the said issue has
been considered by the Assessing Officer and the mere fact that the
assessment order may not contain reference/discussion with regard to the
same would not dilute or take away the fact that the issue was in fact
examined and decided upon by the Assessing Officer, thus a
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revisit/reassessment on such issues would constitute change of opinion
which is impermissible. In this regard, it may be relevant to refer to the
judgment of the Bombay High Court in the case of Aroni Commercials Ltd.
v. Dy. CIT reported in (2014) 362 ITR 403 (Bom) wherein it was held as
under:
“14. ..... It is not necessary that an assessment order should
contain reference and/or discussion to disclose its satisfaction in
respect of the query raised. Therefore, the entire proceeding for
reopening the assessment had emanated only on account of change
of opinion on the part of the Assessing Officer.”
11. Secondly, there is no finding of failure on the part of the petitioner
to fully and truly disclose material particulars necessary for assessment.
The above is a jurisdictional fact and a condition precedent for invoking
power of reassessment under Section 148 of the Act after expiry of four
years from the end of relevant assessment year which is admittedly the case.
Absence of finding of failure to fully and truly disclose material particulars
necessary for assessment would vitiate the impugned proceedings for re-
assessment. In this regard it may be relevant to refer to the following
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judgment:
i) Durr India Pvt. Ltd. v. Asst. CIT, reported in (2023) 455 ITR 460:
“12. From the above decisions, it is clear that existence of
"jurisdictional fact" is sine qua non for the exercise of power. If the
jurisdictional fact exists, the authority can proceed with the case and
take an appropriate decision in accordance with law. It leaves no
room for any doubt that to invoke the extended period, the Assessing
Officer ought to show/demonstrate the existence of any of the three
circumstances set out in the proviso to section 147. In this case,
failure on the part of the assessee to fully and truly disclose all
material particulars in our view would constitute the "jurisdictional
fact" for invoking extended period of limitation and failure to record
the existence of the above jurisdictional fact while invoking the
extended period under the proviso to section 147 of the Act, would
vitiate the entire proceedings. In this regard, it may be relevant to
refer the following judgments, wherein it was held that failure to
render a finding as to the existence of the above circumstance
warranting invocation of the extended period in terms of the proviso
to section 147 of the Act would vitiate the entire proceedings.
(a) Duli Chand Singhania v. Asst. CIT [2004] 269 ITR 192
(P&H) (headnote) :
".. . that the reasons recorded for issue of notice showed that
the satisfaction recorded therein was merely about the escapement of
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income. There was not even a whisper of an allegation that such
escapement had occurred by reason of failure on the part of the
assessee to disclose fully and truly all the material facts necessary
for his assessment. Absence of this finding which is a 'sine qua non'
for assuming jurisdiction under section 147 of the Act in a case
falling under the proviso thereto, made the action taken by the
Assessing Officer wholly without jurisdiction. The notice was not
valid and was liable to be quashed."
(b) CIT v. Elgi Ultra Industries Ltd. [2008] 296 ITR 573
(Mad) (page 577 of 296 ITR) :".. . the reopening of the assessment
under section 148 beyond the period of four years at the end of the
relevant assessment year can be sustained only if it is established
that there is a failure on the part of the assessee to disclose fully and
truly all material facts. In this case there is no finding that there is
failure on the part of the assessee to disclose fully and truly all
material facts."
12. This Court is conscious that while remedy by way of judicial
review the power under Article 226 of Constitution is discretionary and
Courts would exercise restraint when there are statutory remedies, more so
when adjudication is yet to be concluded. However, the above rule is not
without exceptions, one such exception is where the proceedings are
without jurisdiction. In this case this Court has already found that the
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invocation of power of re assessment under Section 147 read with Section
148 of the Act is bad for want of jurisdiction for 2 reasons viz.,
a) The re assessment proceedings is made on the basis of mere cange
of opinion,
b) Absence of finding of failure on the part of the petitioner to fully
and truly disclose material particulars necessary for assessment either in the
notice nor in impugned order under Section 148 A (d) of the Act.
12.1. In this regard it may be relevant to refer to the judgment of the
Supreme Court in the case of Raza Textiles Ltd. v. ITO, reported in (1973)
1 SCC 633, wherein it was held as under:
“3. ..... No authority, much less a quasi-judicial authority, can
confer jurisdiction on itself by deciding a jurisdictional fact wrongly.
The question whether the Jurisdictional fact has been rightly
decided or not is a question that is open for examination by the High
Court in an application for a writ of certiorari. If the High Court
comes to the conclusion, as the learned Single Judge has done in
this case, that the Income Tax Officer had clutched at the
Jurisdiction by deciding a jurisdictional fact erroneously, then the
assessee was entitled for the writ of certiorari prayed for by him. It
is incomprehensible to think that a quasi-judicial authority like the
Income Tax Officer can erroneously decide a jurisdictional fact and
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thereafter proceed to impose a levy on a citizen. In our opinion, the
Appellate Bench is wholly wrong in opining that the Income Tax
Officer can “decide either way”.
13. In view of the above this Court is inclined to set aside the
impugned order. The writ petition stands disposed of. No costs.
Consequently, connected miscellaneous petition is closed.
18.03.2025
Index : Yes/No
Neutral Citation : Yes/No
mrn/spp
To:
The Deputy Commissioner of Income Tax
Corporate Circle 5(2)
4th Floor, Aayakkar Bhawan,
121, Mahatma Gandhi Road,
Nungambakkam,
Chennai -600 034.
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MOHAMMED SHAFFIQ, J.
mrn/spp
and
18.03.2025
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