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Citation Codes
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citation codes
Case Number
Attorney(S)
  • Mr. A. Ramachandran for Messrs. Row and Reddy for the Petr.
  • Mr. C.S Rama Rao Sahib for Respts.
Judges
  • Rajagopalan
  • Rajagopala Ayyangar, JJ.
Acts
  • 12,346. 3. Act 25 of 1953, which amended Section 35 of the Income-tax Act (hereinafter referred to as the Act) and added Sub-clause (5) to Section 35,
  • Section 34 and Section 35 (1) provided. Section 35 (5)
  • provisions of Section 35 (1). Section 35 (1)
  • Section 1 (2) of Act 25 of 1933
  • provisions of Sub-section (1)
  • provisions of Section 35 (5)
  • provisions of Section 35 (1)
  • provision in Section 35 (5)
  • Section 35 (5) to the Act.
  • 24-5-1953, Section 35 (5)
  • 14. Section 35 (5)
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Cites
Cited by
Citation Codes
Equivalent Citations
citation codes
Case Number
Attorney(S)
  • Mr. A. Ramachandran for Messrs. Row and Reddy for the Petr.
  • Mr. C.S Rama Rao Sahib for Respts.
Judges
  • Rajagopalan
  • Rajagopala Ayyangar, JJ.
Acts
  • 12,346. 3. Act 25 of 1953, which amended Section 35 of the Income-tax Act (hereinafter referred to as the Act) and added Sub-clause (5) to Section 35,
  • Section 34 and Section 35 (1) provided. Section 35 (5)
  • provisions of Section 35 (1). Section 35 (1)
  • Section 1 (2) of Act 25 of 1933
  • provisions of Sub-section (1)
  • provisions of Section 35 (5)
  • provisions of Section 35 (1)
  • provision in Section 35 (5)
  • Section 35 (5) to the Act.
  • 24-5-1953, Section 35 (5)
  • 14. Section 35 (5)
See more information ...
Smart Summary

Structured Summary of the Provided Opinion

Factual and Procedural Background

The assessee, the late S. K. Mohideen, was a partner in multiple firms including Dinshaw & Co. and Palaniappa Chettiar (Jupiter Pictures). His individual assessments for the years 1946-47 and 1947-48 were completed on 20-2-1950, provisionally accepting his estimated shares of partnership losses (shown as Rs. 20,000 and Rs. 10,000 for Dinshaw & Co. for 1946-47 and 1947-48 respectively, and Rs. 12,436 for Palaniappa Chettiar for 1947-48).

Subsequent completed assessments of the firms established different figures: Dinshaw & Co.'s assessment (completed 31-10-1950) fixed the assessee's share at Rs. 15,839 (1946-47) and Rs. 1,046 (1947-48); Palaniappa Chettiar's assessment (completed 30-6-1951) fixed the share at Rs. 2,009 (1947-48).

Act 25 of 1953 amended Section 35 of the Income-tax Act by adding Sub-section (5). Although the Act received presidential assent on 24-5-1953, Section 1(2) directed that this amendment be deemed to have come into force on 1-4-1952.

On 4-5-1953, the Income-tax Officer issued a notice under Section 35 seeking to rectify the assessee's 1946-47 and 1947-48 assessments on the basis of the completed firm assessments. The Income-tax Officer later (by order dated 27-3-1954) revised the assessee's assessments and demanded additional tax (Rs. 847-14-0 for 1946-47 and Rs. 16,984-11-0 for 1947-48). By 27-3-1954 the four-year period under Section 35(1), computed from the original assessment date 20-2-1950, had expired.

The assessee died on 17-4-1954; his son (the petitioner) challenged the rectification, arguing that the rectification power was barred by limitation and that Section 35(5) could not apply to assessments completed before 1-4-1952. The Commissioner rejected the petitioner's request to set aside the Income-tax Officer's rectification orders by an order dated 30-9-1955, and also directed rectification in relation to 1948-49 (to the petitioner's potential benefit). The petitioner attacked only the validity of rectifications for 1946-47 and 1947-48 in these proceedings.

Legal Issues Presented

  1. Whether Section 35(5) of the Income-tax Act (as added by Act 25 of 1953 and deemed effective from 1-4-1952) can be applied to assessments which were completed before 1-4-1952.
  2. Whether the rectifications of the assessee's assessments for 1946-47 and 1947-48 made by the Income-tax Officer on 27-3-1954 were barred by limitation under Section 35(1) (four-year period from date of original assessment 20-2-1950).
  3. Whether the Income-tax Officer had jurisdiction to rectify the assessments on 27-3-1954 either under Section 35(1) or under the newly enacted Section 35(5), given the timing of completion of the firm assessments and the retrospective dating of Section 35(5).

Arguments of the Parties

Petitioner's (Assessee's) Arguments

  • Section 35(5) could not be applied to any assessment completed before 1-4-1952; thus the rectifications for 1946-47 and 1947-48 were invalid under that subsection.
  • The power to rectify under Section 35(1) was barred by the four-year limitation computed from 20-2-1950, and the rectification order of 27-3-1954 fell outside that period.
  • The petitioner pointed out that the Income-tax Officer had refused to rectify the 1948-49 assessment (also completed on 20-2-1950), and that relief would have been available had that rectification been allowed—implying inconsistency in the Department's treatment.

Respondent's (Department's) Arguments

  • The 1946-47 and 1947-48 assessments did not become final on 20-2-1950 because they could be re-opened under Section 34 or under Section 35(1) within the four-year period; therefore the Department could validly rely on Section 35(5) once it was deemed effective from 1-4-1952.
  • Section 35(5) extended the period of limitation for rectification by permitting computation of the four-year period from the date of the final order passed in the case of the firm (i.e., the firm assessments completed later), so the Department retained the right to re-open the partner's assessment after 1-4-1952 within the period allowed by s35(5).
  • The assessee had no vested right to finality so long as the statutory power to re-open or rectify the assessment subsisted; a subsequently conferred statutory right (Section 35(5)) could be validly exercised within its time limits.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
K. Lakshminarayana Chetti v. First Addl. Income-tax Officer, Nellore — 1956-29 ITR 419; AIR 1957 Andh-Pra 159 Used for the proposition that Section 35(5) was not merely declaratory of a pre-existing law (i.e., it introduced a legal fiction and a new class of rectifiable mistakes). The court expressly agreed with the dictum of Subba Rao, C.J., cited in this case, endorsing that Section 35(5) was not declaratory of prior law but created a new category of "fictional" mistakes capable of rectification.
Commissioner of Income-tax, Bombay Presidency & Aden v. Messrs. Khemchand-Ramdas — 1938-8 ITR 414; AIR 1938 PC 175 Establishes that the statutory provisions (Sections 34 and 35) are exhaustive as to the circumstances and time within which fresh assessments or notices of demand can be issued. The court relied on this authority to emphasise that powers to re-open assessments must be exercised within the specific statutory provisions and time limits; this supported the conclusion that the Income-tax Officer lacked jurisdiction to re-open the assessments outside the statute's limits.

Court's Reasoning and Analysis

The court proceeded through a sequence of factual findings and statutory analysis:

  1. Timeline and provisional character of the assessee's assessments: The assessments of the assessee (20-2-1950) had expressly recorded that the firm assessments were not completed and that the assessee's shares were provisionally accepted pending completion of the firms' assessments. The later completion of the firm assessments established different figures for the assessee's shares.
  2. Distinction between Section 35(1) and Section 35(5): Section 35(1) is a general provision allowing rectification of "mistake apparent from the record" within four years from the date of the assessment order. Section 35(5), as enacted and deemed effective from 1-4-1952, creates a legal fiction that where a partner's share was omitted or incorrectly included such inclusion or correction "shall be deemed to be a rectification of a mistake apparent from the record" and directs that the four-year period in s35(1) be computed from the date of the final order in the firm's case.
  3. Applicability of s35(1) in the present facts: The court observed that, on the facts, the assessee's case could have been rectified under s35(1) because the provisional figures were shown in the assessment order and the completed firm assessments established the correct figures—this would amount to a mistake apparent from the record as tested by other parts of the record. However, such rectification under s35(1) would have had to be effected within four years from 20-2-1950; the rectification on 27-3-1954 was outside that period and therefore could not be sustained under s35(1).
  4. Nature and effect of s35(5): Section 35(5) authorises rectification of a new class of mistakes (those not previously apparent on the face of the record) by deeming them to be mistakes apparent from record and by allowing computation of the four-year period from the firm's final order. The court emphasised that s35(5) operates by legal fiction and is not merely declaratory of what s35(1) already allowed.
  5. Retrospective operation and limits of s35(5): Although s35(5) was given retrospective effect to 1-4-1952 by Act 25 of 1953, the court found no express provision (and no necessary intendment) in s35(5) to make it applicable to assessments completed before 1-4-1952. Section 35(1) remained intact and its limitation period could not be enlarged merely because s35(5) came into force with retrospective dating; s35(5) created an independent power but did not expressly reach assessments already completed prior to 1-4-1952.
  6. Statutory limitation and jurisdictional conclusion: Relying on the principle (from Khemchand-Ramdas) that powers to re-open assessments must be exercised within the statutory provisions and time limits, the court held that the Income-tax Officer lacked jurisdiction on 27-3-1954 to rectify the assessments for 1946-47 and 1947-48. Rectification under s35(1) was time-barred; s35(5) could not be invoked in respect of assessments completed before the deemed commencement date (1-4-1952).
  7. Procedural consequence: The Commissioner’s confirmation of the Income-tax Officer's rectifications for 1946-47 and 1947-48 (order dated 30-9-1955) was also set aside. The court noted the Commissioner had directed rectification for 1948-49 in the petitioner's favour, but emphasised the petitioner could not retain that benefit while avoiding liability imposed by the same orders if those orders were to be set aside.

Holding and Implications

Holding: The petition is allowed and the orders of the Income-tax Officer dated 27-3-1954 and the Commissioner dated 30-9-1955, insofar as they relate to assessment years 1946-47 and 1947-48, are set aside.

Implications (direct consequences as stated in the opinion):

  • The rectifications of the assessee's assessments for 1946-47 and 1947-48 were invalid for want of jurisdiction (the four-year limitation under Section 35(1) had expired and Section 35(5) could not be applied to assessments completed before 1-4-1952).
  • The entire order of the Commissioner dated 30-9-1955 and the Income-tax Officer's orders relating to those assessment years were set aside, and no costs were awarded.
  • The court articulated that Section 35(5) creates a legal fiction enabling a new class of rectifications (deemed mistakes apparent from the record) and that such power, when conferred, does not by necessary implication operate retrospectively to assessments completed prior to the deemed commencement date unless the statute expressly so provides.

The opinion did not expressly state whether it intended to create a binding precedent beyond resolving this dispute, beyond the court's reasoned interpretation that Section 35(5) could not be applied to assessments completed before 1-4-1952 and that s35(1)'s limitation could not be enlarged by implication.

Show full summary ...

    S.K Habibtjllah v. The Income-Tax Officer, V Circle, Madras And Another.

    1. The petitioner is the son of the late S. K. Mohideen, hereinafter referred to as the assessee. The assessee was a partner of Dinshaw and Co., and of the firm Palaniappa Chettiar (Jupiter Pictures) among other concerns. The assessment of Mohideen for the assessment years 1946-47 and 1947-48 was completed on 20-2-1950. By that date the assessment of the firm ot Palaniappa Chettiar for 1947-48 and that of Dinshaw and Co. for the years 1946-47 and 1947-48 had not been completed, Mohideen's assessment was, however, completed, accepting provisionally his estimates of his share of the losses of those two partnership concerns. The assessee's share of the losses of Dinshaw and Co., was shown as Rs. 20,000 for 1946-47 and as Rs. 10,000 for 1947-48, and his share of the losses in the firm of Palaniappa Chettiar for 1947-48 was shown as Rs. 12,436.

    2. The assessment of Dinshaw and Co., for both the years was completed on 31-10-1950. As against the Rs. 20,000 provisionally accepted as the assessee's share of the loss for 1946-47, Rs. 15,839 was ascertained as his share. For the assessment years 1947-48 the assessee's share of the loss was ascertained as Rs. 1,046; the provisional basis for assessment was Rs. 10,000. The assessment of the firm of Palaniappa Chettiar for 1947-48 was completed on 30-0-1951 when the assessee's share of the losses was determined as Rs. 2,009 as against the provisionally accepted figure of Rs. 12,346.

    3. Act 25 of 1953, which amended Section 35 of the Income-tax Act (hereinafter referred to as the Act) and added Sub-clause (5) to Section 35, received the assent of the President on 24-0-1953. But, as Section 1 (2) of Act 25 of 1933 directed that this amendment among others should be deemed to have come into force on 1-4-1952, the position was as if Section 35 (5) had become part of the Act on 1-4-1952.

    4. On 4-5-1953, that is, even before act 25 of 1933 received the assent of the -President, the Income-tax Officer issued a notice to the assessee under Section 35 of the Act to show cause why the assessment for 1946-47 and 1947-48 should not be rectified on the basis of the completed assessments of Dinshaw and Co., and Palaniappa Chettiar. The assessee represented that that could be done if the law permitted it. The Income-tax Officer, however, recorded:

    "The assessee in his reply dated 24-3-1954 intimated that he has no objection to the revision of the assessment."

    It was not disputed that as a statement of fact this was incorrect. The Income-tax Officer revised the assessment of the assessee for 1946-47 and 1947-48 by his order dated 27-3-1854. An additional tax of Rs. 847-14-0 was demanded for 1946-47. The additional tax for 1947-48 that was demanded was Rs. 16,984-11-0. By 27-3-1954 the period of four years for which Section 35 (1) of the Act provided, computed from the date of the original assessment 20-2-1950, had expired.

    5. The assessee Mohideen died on 17-4-1954. His son, the petitioner, moved the Commissioner of Income-tax, to revise the orders of the Income-tax Officer dated 27-3-1954 on the grounds, that the power to rectify the assessment of 1946-47 and 1947-48 under Section 35 was barred by limitation, and that Section 35 (5) could not apply to assessments completed before 1-4-1952. The petitioner also pointed out to the Commissioner that the Income-tax Officer had refused the petitioner's request to rectify the assessment for 1948-49, the original assessment for which also had been completed on 20-2-1930. The petitioner would have been entitled to some relief had that rectification been allowed.

    6. By his order dated 30th September 1953, the Commissioner rejected the petitioner's request to set aside the orders of the Income-tax Officer directing the rectification of the assessment for 1946-47 and 1947-48. The Commissioner, however, instructed the Income-tax Officer:

    ''As a corollary, the relief prayed for the assessment for 1948-49 by incorporating the correct share income should be allowed and if necessary to that extent to revise the 1949-50 assessment." The relevant portion of Section 35 (1) ran:

    "The Income-tax Officer may at any time within four years from the date of any assessment order .......passed by him on his own motion rectify any mistake apparent from the record of .............. the assessment..........and shall within like period rectify any such mistake which has been brought to his notice by an assessee."

    Section 35 (5) which as we pointed out must be deemed to have been part of the Act on 1-4-1952 ran:

    "Where in respect of any completed assessment of a partner in a firm it is found on the assessment r re-assessment of the firm, or on any reduction or enhancement made in the income of the firm....... that the share of the partner in the profit or loss of the firm has not been included in the assessment of the partner or if included, is not correct, the inclusion of the share in the assessment or the correction thereof, as the case may be, shall be deemed to be a rectification of a mistake apparent from the record within the meaning of this section, and the provisions of Sub-section (1) shall apply thereto accordingly, the period of four years referred to in that sub-section being computed from the date of the final order passed in the case of the firm."

    7. The principal contention of the learned counsel for the assessee was that the provisions of Section 35 (5) could not be applied to any assessment completed before 1-4-1952. He relied on K. Lakshminarayana Chetti v. First Addl, Income-tax Officer Nellore, 1956-29 ITR 419: (AIR 1957 Andh-Pra 159) (A).

    8. The defence of the learned counsel for the Department was on the following lines. The assessments for 1946-47 and 1947-48 did not become final when they were completed on 20-2-1950 because they could be re-opened either under Section 34 or under Section 35 (1) of the Act within the time of four years allowed by either of these provisions. Before that period of four years expired Section 35 (5) of the Act came into force on 1-4-1952. That extended the period of limitation to re-open and correct an assessment, as the period of four years allowed by Section 35 (5) could be computed not from 20-2-1950, the date of the original assessment, but from 31-10-1950 and 30-6-1951, the dates of the final orders in the case of the firms of which the assessee was a partner. In other worlds, the assessee had no vested right to any finality of the assessments completed on 20-2-1950, so long as the Department had the right to re-open an assessment under Section 34 or under Section 35 of the Act. As within that period a further right was conferred on the Department by Section 35 (5), that right could be validly exercised within the time prescribed by Section 35 (5).

    9. In Commr. of Income-tax, Bombay Presidency and Aden v. Messrs. Khemchand-Ramdas, 1938-8 ITR 414: (AIR 1938 PC 175) (B), their Lordships of the Privy Council, after referring to the terms of Section 34 and Section 35 of the Act observed at p. 426 (of ITR): (at p. 180 of AIR):

    "In view of these express provisions of the Act it is in their Lordships' opinion quite impossible to suppose that the Income-tax Officer may in every kind of circumstance and after any lapse of time make a fresh assessment or issue fresh notice of demand........In their Lordships' opinion the provisions of the two sections are exhaustive and prescribe the only circumstance in which and the only lime in which such fresh assessments can be made and fresh notices of demand can be issued."

    10. Whether the assessee's case could have been re-opened under Section 34 of the Act does not arise for consideration in these proceedings for the simple reason that Section 34 was never invoked. It was the power to rectify that was vested in the Income-tax Officer by Section 35 of the Act that was invoked. On 4-5-1953, when the Income-tax Officer invoked these powers and issued notices to the assessee, Section 35 (5) had not yet been enacted, but when it was enacted on 24-5-1953, Section 35 (5) was given effect from an anterior date 1-4-1952. Thus the Income-tax Officer has jurisdiction to exercise the powers vested in him by Section 35 (1) as well as those vested in him by Section 35 (5) on 4-5-1953 and thereafter.

    11. There is one feature of this case to which we shall advert at this stage. The learned counsel for the Department was, in our opinion, right in his contention, that in the circumstances of this case, the assessment of Mohideen for 1946-47 and 1947-48 could have been rectified under Section 35 (1) itself, as it was really a case of rectifying a mistake apparent on the face of the record of assessment. The assessment orders dated 20-2-1950 specifically referred to the shares of the assessee in the looses sustained by the two firms of which he was a partner, Dinshaw and Co., and Palaniappa Chettiar. They were determined on a provisional basis. The determination was provisional till the assessments of Dinshaw and Co., and Palaniappa Chettiar could be completed. The assessment orders specifically recorded that the assessments of Dinshaw and Co., and Palaniappa Chettiar had not been completed. That made the assessment orders in relation to Dinshaw & Co. and Palaniappa Chettiar part of the assessee's record of assessment. That the figures shown in the orders of the assessee's assessments on 20-2-1950 were incorrect, tested by another portion of the record of that assessment, the assessment of Dinshaw and Co., and Palaniappa Chettiar which were completed only later, did not admit of any controversy. The assessment of Dinshaw and Co., was completed on 31-10-1950 and that of Palaniappa Chettiar on 30-6-1951. At any time thereafter, when the mistake on the face of the assessee's record of assessment was established, the Income-tax Officer could have rectified the assessment of the assessee under Section 35 (1), But that rectification could have been validly effected only if it had been ordered within four years from 20-2-1950, as that was all the period for which Section 35 (1) provided. The rectification ordered on 27-3-1954 fell outside that period.

    12. That, however, does not lead to the conclusion that every case of rectification necessitated by the fact, that an assessee's share of the profits or losses of a firm of which he was a partner had been either omitted of had been incorrectly assessed, would be a rectification within the scope of Section 35 (1). That in a given case, the assessee's for example, such a rectification could fall within Section 35 (1) as well as under Section 35 (5) does not mean that every such rectification could be dealt with under either subsection. Section 35 (1) is a general provision. Section 35 (5) is not a special provision for rectification in the contingency specified; it provided for rectification on the basis of a legal relations fiction. Section 35 (5) directs that where the share of the partner in the profit or loss of the firm has not been included in the assessment of the partner or if included is not correct, the inclusion of the share in the assessment or the correction thereof shall be deemed to be a rectification of a mistake apparent from the record within the meaning of Section 35. Therefore, even if it is not a case of a mistake apparent from the record or on the face of the record of assessment, it is deemed to be such a mistake; and thereafter the provisions of Section 35 (1) apply, subject however, to the period of limitation prescribed by Section 35 (1) being computed from the date specified in Section 35 (5). The necessity to enact a legal fiction by which something which is not a mistake apparent on the face of the record is deemed to be such a mistake is wholly inconsistent with the view, that Section 35 (5) was merely declaratory of the previous law on the subject as embodied in Section 35 (1) and as implied in these provisions.

    13. We are in respectful agreement with the dictum of Subba Rao, C. J., in 1956-29 ITR 419 at p. 425: (AIR 1957 Andh Pra 159 at p. 161) (A), that Section 35 (5) was not declaratory of a pre-existing law.

    14. Section 35 (5) authorised a new class of mistakes to be rectified; what had not hitherto been a mistake apparent on the face of the record of assessment within the meaning of Section 35 (1) became such a mistake by the operation of the legal fiction enacted by Section 35 (5). That mistake also could thereafter be rectified in addition to the mistakes for the rectification of which provision had already been made in Section 35 (1). The power to rectify what we can conveniently refer to at this stage as 'fictional' mistakes was vested in the Income-tax Officer on 1-4-1952. There was no express provision in Section 35 (5) to make it apply to assessments completed before 1-4-1952. Nor can we find anything in the language of Section 35 (5) which could sustain a plea, that by necessary intendment Section 35 (5) applied also to assessments completed before 1-4-1952.

    15. Neither in express terms nor by necessary intendment did Section 35 (5) in any way amend the provisions of Section 35 (1). Section 35 (1) was left intact even after the addition of Section 35 (5) to the Act. Therefore the fact that on 1-4-1952, when Section 35 (5) came into force, the period of limitation prescribed by Section 35 (1) had not run out in the case of the assessee, could not enlarge the period of limitation prescribed by Section 35 (1). It was independent of Section 35 (1) that the powers under Section 35 (5) could be invoked. That the period of limitation prescribed by Section 34 had not expired in the case of the assessee on 1-1-1952 had even less relevancy. The assesse's case was not dealt with under Section 34. It was not dealt with under Section 35 (1). It could not have been dealt with under Section 35 (1) after the expiry of four years reckoned from the date of the original assessment 20-2-1950. That left only Section 35 (5), which, as we have pointed out, conferred a power independent of those for the exercise of which Section 34 and Section 35 (1) provided. Section 35 (5) could not apply, as the assessment in this case had been completed long before 1-4-1952, when a fresh power to rectify assessments was conferred on the Income-tax Officer. As pointed out in 1938-6 ITR 414: (AIR 1938 PC 175) (B), the power to re-open an assessment must be sought within the limits of the specific statutory provisions. It may not be necessary to put it solely on the basis that the assessee has a vested right to claim finality of assessment. The question, in our opinion, really is what was the statutory power that was exercised? What was the jurisdiction of the Income-tax Officer to re-open an assessment? That power and that jurisdiction must be based upon a specific statutory provision in the Act. In the case of assessee the power given by Section 35 (1) could not have been exercised on 27-3-1954. That given by Section 35 (5) should not have been exercised in relation to assessments completed before 1-4-1952. In our opinion, on 27-3-1954, the Income-tax Officer had no jurisdiction to rectify the assessments of the assessee for the assessment years 1946-47 and 1947-48.

    16. The learned counsel for the Department pointed out that the order of the Commissioner dated 30th September 1955 confirmed the rectification ordered by the Income-tax Officer with reference to the assessment years 1946-47 and 1947-48, and further directed rectification of the assessment for 1948-49, under which the petitioner would be entitled to a considerable amount of relief. The petitioner in these proceedings attacked only the validity of the rectification ordered by the Income-tax Officer and confirmed by the Commissioner with reference to the assessment for the assessment years 1946-47 and 1947-48. The learned counsel for the Department was right in his contention, that the assessee should not be permitted by any order of ours to retain a benefit that accrues to him under the order dated 30-9-1955, while avoiding the liability imposed upon him by that order.

    17. The petition is allowed and the rule will be made absolute. The entire order of the Commissioner dated 30-9-1955 and the orders of the Income-tax Officer in relation to the assessment years 1946-47 and 1947-48 will stand set aside. No costs.

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    Comments

    S.K Habibtjllah v. The Income-Tax Officer, V Circle, Madras And Another.
    (Apr 10, 1957)