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Smart Summary

Factual and Procedural Background

The petition under article 226 of the Constitution challenged two notices dated January 22, 1987 and March 18, 1987 issued by the Commissioner of Income-tax, Central, Bombay under section 263 of the Income-tax Act, 1961. The notices related to the petitioners' assessments for assessment years 1982-83 and 1983-84.

The assessments had been completed by the Income-tax Officer under section 143(3) read with section 144B on February 11, 1985 and March 24, 1986 respectively. Appeals against those assessments were filed on March 12, 1985 and April 4, 1986 and were dismissed. Second appeals to the Tribunal remained pending when the Commissioner issued the impugned section 263 notices.

The Commissioner stated the reason for issuing the notices was that the petitioners had collected amounts (Rs. 12,33,227 and Rs. 3,14,146 respectively) from customers on account of "Hotel receipts tax" which were neither paid to the Government nor refunded to customers during the relevant years, and yet the Income-tax Officer had not treated these receipts as trading receipts or part of income, making the assessment orders erroneous and prejudicial to the interests of the Revenue.

Legal Issues Presented

  1. Whether the Commissioner had jurisdiction under section 263 to issue revisionary notices after the assessment orders had been the subject of appeal and had merged in the appellate orders, as per this court's decisions in CIT v. P. Muncherji and Co. and CIT v. A.S. Narendrakumari Basaheba.
  2. Whether retrospective amendments (in particular Explanation (c) to section 263(1) as inserted and later amended) alter the merger effect of appellate disposal so as to permit the Commissioner to proceed under section 263 in the facts of this case.
  3. As a factual/merits matter raised by the Department: whether amounts collected as "Hotel receipts tax" constitute trading receipts taxable as income (as relied upon by the Department from Supreme Court precedents).

Arguments of the Parties

Petitioners' Arguments (Shri Rajgopal)

  • Challenged the Commissioner's jurisdiction to initiate proceedings under section 263 on the ground that the assessment orders had merged into the appellate orders once appeals were filed and disposed of, relying on this court's decisions in CIT v. P. Muncherji and Co., [1987] 167 ITR 671 and Commissioner of Income-Tax v. Smt. A.S. Narendrakumari Basaheba, [1989] 176 ITR 515.

Department's Arguments (Shri Jetley)

  • Submitted that there was a pending question before the Supreme Court about whether the whole assessment order merges on appeal or only that portion which was the subject-matter of the appeal, pointing to a conflict of views among High Courts.
  • Admitted that in this court the binding view was that the whole assessment order merges into the appellate order once an appeal is filed and disposed of.
  • Contended that the retrospective amendment (Explanation (c) to section 263(1) inserted effective June 1, 1988 and subsequently amended with retrospective effect by Finance Act, 1989) limited merger only to matters actually considered and decided in appeal, and therefore supported the Commissioner's jurisdiction in the present case.
  • Relied on Supreme Court decisions (Chowringhee Sales Bureau (P) Ltd. v. CIT and Sinclair Murray and Co. P. Ltd. v. CIT) to argue that the amounts collected as "Hotel receipts tax" were trading receipts taxable as income; however, he accepted that this question was not material for the present petition because, if jurisdiction were upheld, the Commissioner could decide the merits.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
CIT v. P. Muncherji and Co., [1987] 167 ITR 671 The principle that once an assessment order is the subject-matter of an appeal and the appeal is disposed of, the whole of the assessment order merges in the appellate order. The court treated this decision as binding on it and applied the merger principle to conclude that the Commissioner lacked jurisdiction under section 263 to issue the impugned notices.
Commissioner of Income-Tax v. Smt. A.S. Narendrakumari Basaheba, [1989] 176 ITR 515 Reaffirmation of the merger doctrine: appellate disposal results in merger of the assessment order into the appellate order. The court relied on this decision alongside Muncherji to hold that the assessment orders had merged in the appellate orders and that the Commissioner therefore had no jurisdiction to revise those assessments under section 263.
Chowringhee Sales Bureau (P) Ltd. v. CIT, [1973] 87 ITR 542 Authority cited to support the proposition that certain receipts can constitute trading receipts taxable as income. The court recorded that the Department relied on this Supreme Court decision to argue the collected amounts were trading receipts; but the court noted that this point was not material to the adjudication of the jurisdictional challenge in the petition and could be decided later by the Commissioner if jurisdiction were sustained.
Sinclair Murray and Co. P. Ltd. v. CIT, [1974] 97 ITR 615 Authority cited to support the proposition that certain receipts can be treated as trading receipts and taxable. The court noted the Department's reliance on this decision for the trading-receipts argument but observed that it was not decisive for the present petition on jurisdiction; merits could be examined by the Commissioner if jurisdiction were established.

Court's Reasoning and Analysis

The court began by acknowledging the binding nature of its earlier decisions in CIT v. P. Muncherji and Co. and CIT v. A.S. Narendrakumari Basaheba, which hold that once an assessment order has been the subject-matter of an appeal and that appeal has been disposed of, the entire assessment order merges into the appellate order. Consequently, the central issue became whether later legislative amendments to section 263—specifically Explanation (c) to section 263(1)—overrode or nullified the effect of those judgments.

The court set out the text of section 263(1) and its Explanations, noting the history of insertion and amendment:

  • Explanation (c) was originally inserted by the Taxation Laws (Amendment) Act, 1984 effective October 1, 1984, but initially contained only clauses comparable to current Explanation (a) and (b) (the original Explanation (c) as inserted by the Finance Act, 1988, read prospectively from June 1, 1988).
  • Explanation (c) as inserted by the Finance Act, 1988 read: where an order passed by the Assessing Officer had been the subject-matter of any appeal, the Commissioner's powers under section 263 would extend to matters not considered and decided in such appeal (i.e., prospectively effective from June 1, 1988).
  • The Finance Act, 1989 later introduced additional wording—namely the phrases “filed on or before or after the 1st day of June, 1988” and “and shall be deemed always to have extended”—and stated that insertion to be retrospective to June 1, 1988.

The court analysed the effect of that amendment. Although at first blush the 1989 amendment might appear to give the Department the broader retrospective reach it sought, the court held that Explanation (c) must be construed harmoniously and sensibly. The court reasoned that an amendment cannot have retrospective effect earlier than the date on which the provision sought to be amended was initially brought onto the statute book. Therefore, the additional words introduced in 1989 must be read as if they were present only from the date the Explanation itself was inserted (June 1, 1988).

The court concluded that Explanation (c) operates only from June 1, 1988 onwards so that only in cases where action under section 263 is taken after June 1, 1988 will merger be confined to the issues actually considered and decided in appeal. Because, in the present case, the appeals were not only filed but were disposed of before June 1, 1988, Explanation (c) had no effect to alter the pre-existing merger rule as established by this court's precedents. Consequently, the Commissioner had no jurisdiction to initiate section 263 proceedings in respect of these assessment orders.

Holding and Implications

Holding: The petition succeeds: the impugned notices issued under section 263 are invalid and the rule is made absolute in terms of prayer (a).

Implications:

  • Direct effect on the parties: The Commissioner's notices dated January 22, 1987 and March 18, 1987 issued under section 263 are quashed for want of jurisdiction because the assessment orders had merged into the appellate orders in accordance with this court's binding decisions. The petition is allowed and there is no order as to costs.
  • Broader effect: The court's decision is based on applying this court's earlier merger doctrine and on a construction of Explanation (c) to section 263(1) that limits its effect to actions taken on or after June 1, 1988. The opinion does not purport to set a new principle beyond this construction and its application to the facts; it applies existing precedent to the case at hand.

This summary was prepared exclusively from the provided opinion. No information not contained in the opinion has been added.

    Ritz Ltd. And Another v. Union Of India And Others.

    T.D Sugla, J.:— By this petition under article 226 of the Constitution of India, the petitioners have challenged the legality of the two notices dated January 22, 1987, and March 18, 1987, issued by the Commissioner of Income-tax, Central, Bombay, under section 263 of the Income-tax Act, 1961, for the assessment of the petitioners for the assessment years 1982-83 and 1983-84.

    2. The petitioners' assessment for the two years were completed by the Income-tax Officer under section 143(3) read with section 144B of the Income-tax Act, 1961, respectively, on February 11, 1985, and March 24, 1986. Appeals were filed thereagainst before the Commissioner of Income-tax (Appeals) on March 12, 1985, and April 4, 1986. Those were dismissed. Second appeals thereagainst before the Tribunal are still pending. At this stage, the Commissioner issued the impugned notices. The reason given for the issue of the notices was stated to be that the petitioners had collected Rs. 12,33,227 and Rs. 3,14,146 for the two years from the customers on account of “Hotel receipts tax” which amounts were neither paid to the Government nor refunded to the customers during the relevant previous years. Yet the Income-tax Officer had not treated these receipts as trading receipts and part of the income in these years. The orders of assessment were thus erroneous and prejudicial to the interests of the Revenue.

    3. Shri Rajgopal, learned counsel for the petitioners, challenged the jurisdiction of the Commissioner to start proceedings under section 263 on the ground that the orders of assessment had merged in those of the Commissioner of Income-tax (Appeals) as held by this court in the case of CIT v. P. Muncherji and Co., [1987] 167 ITR 671. It was pointed out that the same view was taken by this court in a subsequent decision in the case of Commissioner Of Income-Tax v. Smt. A.S Narendrakumari Basaheba., [1989] 176 ITR 515.

    4. Shri Jetley, learned counsel for the Department, on the other hand, submitted that the question whether the assessment order merged wholly or whether only that portion of it which was, in fact, the subject-matter of appeal merged in that of the appellate order was pending before the Supreme Court, there being a conflict of views amongst the High Courts. He fairly admitted that so far as this court is concerned, the binding decision is that once an appeal is filed against an assessment order and disposed of, the whole of the assessment order merges in the appellate order irrespective of the fact whether a particular aspect of the matter was or was not the subject-matter of appeal.

    5. This argument, according to him, was, however, not of much consequence now in view of the retrospective amendment of section 263. explanation (c) to section 263(1) was inserted with effect from June 1, 1988. After the insertion of that Explanation, only that part of the order of assessment merges in the appellate order which as a matter of fact has been the subject-matter of appeal.

    6. Placing then reliance on the Supreme Court decisions in the cases of Chowringhee Sales Bureau (P) Ltd. v. Cit, West Bengal, [1973] 87 ITR 542 and Sinclair Murray and Co. P. Ltd. v. CIT, [1974] 97 ITR 615, Shri Jetley argued that the amounts collected by the petitioners as “Hotel receipts tax” were trading receipts and as such taxable as income. He fairly admitted that for the purpose of this petition this aspect is not very material as in the event of this court's upholding the Commissioner's jurisdiction to issue notices under section 263, all these questions will have to and could be decided on merits by the Commissioner.

    7. In view of this court's judgments in CIT v. Muncherji (P.) and Co., [1987] 167 ITR 671 and in CIT v. A.S Narendrakumari Basaheba, [1989] 176 ITR 515, the legal position is that once an order of assessment is the subject-matter of appeal, the whole of it merges in that of the appellate order Thus, the only question that requires consideration is whether the retrospective amendment of section 263 overrides or nullifies the effect of those judgments. In order to appreciate the submissions made on behalf of the Revenue, it is desirable to refer to the provisions of section 263(1) along with the Explanations thereto. The provisions read as under:

    “263(1) The Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including an order enhancing or modifying the assessment, or cancelling the assessment and directing a fresh assessment.

    Explanation.— For the removal of doubts, it is hereby declared that, for the purposes of this sub-section,—

    (a) an order passed on or before or after the 1st day of June, 1988, by the Assessing Officer shall include—

    (i) an order of assessment made by the Assistant Commissioner or the Income-tax Officer on the basis of the directions issued by the Deputy Commissioner under section 144A;

    (ii) an order made by the Deputy Commissioner in exercise of the powers or in the performance of the functions of an Assessing Officer conferred on, or assigned to, him under the orders or directions issued by the Board or by the Chief Commissioner or Director General or Commissioner authorised by the Board in this behalf under section 120;

    (b) ‘record’ shall include and shall be deemed always to have included all records relating to any proceeding under this Act available at the time of examination by the Commissioner;

    (c) where any order referred to in this sub-section and passed by the Assessing Officer had been the subject-matter of any appeal filed on or before or after the 1st day of June, 1988, the powers of the Commissioner under this sub-section shall extend and shall be deemed always to have extended to such matters as had not been considered and decided in such appeal.”

    8. The Explanation as such was, admittedly, inserted in section 263 by the Taxation Laws (Amendment) Act, 1984, with effect from October 1, 1984. The Explanation had only two clauses (a) and (b) at that time which are similar to Explanation (a) now. Clause (c) was inserted in the Explanation by the Finance Act, 1988, with effect from June 1, 1988. However, Explanation (c) then did not have the words “filed on or before or after the 1st day of June, 1988” after the words “of any appeal” nor the words “and shall be deemed always to have extended” between the words “shall extend” and “to such matters”. These words were introduced in Explanation (c) by the Finance Act, 1989, some time in April/May 1989, with retrospective effect from June 1, 1988. On first impression Explanation (c), as it stands without anything more, appears to support Shri Jetley's submission that Explanation (c) was applicable in the present case also. On carefully examining the provisions of Explanation (c), however, the position is otherwise. Before its amendment by the Finance Act, 1989, Explanation (c) inserted by the Finance Act, 1988, read as under:

    “Where any order referred to in this sub-section and passed by the Assessing Officer had been the subject-matter of any appeal, the powers of the Commissioner under this sub-section shall extend to such matters as had not been considered and decided in such appeal.”

    9. The Explanation was then evidently prospective with effect from June 1, 1988. In the present case, the appeals having been not only filed but also disposed of before that date, this Explanation would have no effect whatsoever. Coming then to the amendment of the Explanation in 1989 with retrospective effect from June 1, 1988, it is seen that on the face of it there is some contradiction. The insertion of the words “filed on or before or after the 1st day of June, 1988” and “and shall be deemed always to have extended” at two places in the Explanation may support the Department's contention on the fact of it that after the amendment in 1989, Explanation (c) means that to the extent matters have not been considered and decided in appeal the Commissioner will always have jurisdiction to revise the order of assessment under section 263 subject to other conditions. The question, however, is if that was so, why did the Legislature not stop at that and went further to say that the insertion of these words though factually in 1989 was with retrospective effect from June 1, 1988, the date on and from which Explanation (c) itself was inserted by the Finance Act, 1988. In my judgment, Explanation (c) requires to be construed harmoniously. The insertion of the words at two places as well as the fact that the insertion is made retrospective from the date on which the Explanation itself was inserted can all be given proper meaning if it is held that these words are to be read in the Explanation right from the date the Explanation itself was inserted. Thus, only in cases where action under section 263 is taken after June 1, 1988, the merger of the assessment order will be treated as confined to the issues actually considered and decided in appeal in terms of Explanation (c). In my judgment, the construction placed herein is based on sound logic, namely, irrespective of the language in which the amending provisions are couched, the amendment cannot be retrospective with effect from a date earlier to the date on which the provision sought to be amended itself was brought on the statute book.

    10. In the above view of the matter, it has to be held that the impugned notices issued by the Commissioner are invalid inasmuch-as after the merger of the assessment orders in the appellate orders in view of this court's judgments in CIT v. P. Muncherji and Co., [1987] 167 ITR 671 and CIT v. A.S Narendrakumari Basaheba, [1989] 176 ITR 515, he had no jurisdiction to take up proceedings under section 263. Hence, the petition succeeds. Rule is made absolute in terms of prayer (a). No order as to costs.

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    Comments

    Ritz Ltd. And Another v. Union Of India And Others.
    (Mar 23, 1990)