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AMICUS AI
Citation Codes
Equivalent Citations
citation codes
Case Number
Attorney(S)
  • : Dr. Anita Sumanth
  • : Mr. K. Subramanian, Sr. Standing Counsel for Income-tax
Judges
  • Hon'ble Thiru.Justice Elipe Dharma Rao
  • Hon'ble Thiru.Justice M. Venugopal
Acts
  • Section 143(1)(a) of the Income-tax Act, 1959 (hereinafter referred to as "the Act")
  • provisions of section 147, separate clauses (a)
  • SECTION 148 INCOME TAX ACT 1961
  • section 148 read with section 147(a).
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Cites
Cited by
Citation Codes
Equivalent Citations
citation codes
Case Number
Attorney(S)
  • : Dr. Anita Sumanth
  • : Mr. K. Subramanian, Sr. Standing Counsel for Income-tax
Judges
  • Hon'ble Thiru.Justice Elipe Dharma Rao
  • Hon'ble Thiru.Justice M. Venugopal
Acts
  • Section 143(1)(a) of the Income-tax Act, 1959 (hereinafter referred to as "the Act")
  • provisions of section 147, separate clauses (a)
  • SECTION 148 INCOME TAX ACT 1961
  • section 148 read with section 147(a).
See more information ...
Smart Summary

Structured Summary of the Opinion (Judgment delivered by E. Dharma Rao, J.)

Factual and Procedural Background

The assessee-company filed a return of income for the assessment year 1998-99 on 30.10.1998 admitting 'Nil' income; this return was processed under Section 143(1)(a) on 10.05.1999. A revised return was filed on 26.11.1999 (with additional TDS certificates) and processed on 29.03.2001; a further revised order was passed on 27.06.2002 granting an additional refund of Rs. 8,86,226/-.

On review, the Assessing Officer (AO) concluded that the assessee had not computed income correctly under Section 115JA and therefore had reason to believe that income assessable to tax had escaped assessment. Consequently, proceedings under Section 147 were initiated by issuing a notice under Section 148 on 23.12.2003. The assessee's representative wrote on 05.01.2004 requesting that the original return be treated as response to the Section 148 notice. A notice for hearing under Section 143(2) was issued on 16.12.2004 and the assessee's representative attended.

The AO recorded specific reasons for reopening (set out as three points): (A) alleged failure to admit income under Section 115JA on account of claimed unabsorbed depreciation/losses; (B) omission to consider provisions for bad and doubtful debts in computing book profit under Section 115JA; (C) alleged non-crediting to profit & loss account of royalty amounts written back (claimed to be taxable).

The AO, relying partly on precedent, held that the provision for bad and doubtful debts (not written off) did not represent an ascertained liability and should be included in book profit; further, the royalty waiver was treated as taxable income for Section 115JA purposes.

The assessee appealed to the Commissioner of Income Tax (Appeals) [CIT(A)] who, by order dated 17.02.2006, quashed the reassessment on jurisdictional grounds: CIT(A) held that because a notice under Section 143(2) had been issued within time and proceedings were allowed to remain inconclusive, AO lacked jurisdiction to initiate proceedings under Section 148 (citing apex court authority). The Department appealed to the Income Tax Appellate Tribunal (ITAT), which by order dated 15.10.2007 reversed CIT(A), held that no proceedings were pending (time for completion under Section 143(3) had expired), and that initiation under Section 148 was valid; ITAT restored the issue to the file of CIT(A) for fresh decision. The assessee then filed the present tax case appeal before this Court.

Legal Issues Presented

  1. Whether, on the facts and circumstances of the case, the Income Tax Appellate Tribunal was correct in law in holding that issuance of notice under Section 148 of the Income-tax Act is valid when a notice issued under Section 143(2) is pending consideration?

Arguments of the Parties

Assessee's Arguments

  • The Tribunal erred in holding that proceedings under Section 148 were validly initiated; the reassessment should be annulled for lack of jurisdiction.
  • Jurisdiction under Section 147 can be invoked only if proceedings under Section 143(2) have resulted in an assessment or, alternatively, if proceedings under Section 143(2) were never initiated by issuing a notice. Once a notice under Section 143(2) is issued, Section 147 cannot be invoked until that notice has fructified into an order under Section 143(3).
  • Reliance was placed on the Supreme Court decision in TRUSTEES OF H.E.H. NIZAM'S TRUST v. C.I.T. ((2000) 242 ITR 381) for the proposition that reassessment cannot be initiated while assessment proceedings based on the return remain pending.

Revenue / Assessing Officer / Tribunal's Arguments

  • The AO had a bona fide subjective "reason to believe" that income assessable to tax had escaped assessment (errors in computation under Section 115JA; incorrect treatment of provisions for bad debts and royalty write-backs), thereby satisfying the condition for invoking Section 147 as substituted.
  • The time for completing the assessment under Section 143(3) had expired and, at the relevant time, no proceedings were pending before the AO; on that basis issuance of notice under Section 148 was legally permissible.
  • Authorities (including the Supreme Court decision in ASSISTANT COMMISSIONER OF INCOME-TAX v. RAJESH JHAVERI STOCK BROKERS P. LTD. ((2007) 291 ITR 500)) establish that under the post-1989 (substituted) Section 147 the existence of a 'reason to believe' alone suffices to confer jurisdiction to reopen an assessment (subject to the proviso exceptions).
  • On the merits, precedent (DEPUTY CIT v. BEARDS SHELL LTD., 244 ITR 256) was relied upon to treat provisions for bad and doubtful debts not written off as not constituting an 'ascertained liability' and therefore includible in book profit for Section 115JA.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
TRUSTEES OF H.E.H. NIZAM'S TRUST v. C.I.T. ((2000) 242 I.T.R. 381) Principle: A notice for reassessment under Section 148 cannot be issued while assessment proceedings based on the return remain pending; reassessment cannot be initiated until the return already filed is disposed of. The assessee relied on this authority to contend that initiation of reassessment was impermissible while proceedings under Section 143(2) were pending. The opinion records this reliance and the textual formulation of the principle from that decision.
ASSISTANT COMMISSIONER OF INCOME-TAX v. RAJESH JHAVERI STOCK BROKERS P. LTD. ((2007) 291 ITR 500) Principle: Under the substituted Section 147 (with effect from 1.4.1989) the Assessing Officer needs only a 'reason to believe' that income has escaped assessment to confer jurisdiction to reopen; the earlier two-condition test for section 147(a) (pre-substitution) is altered so that only the first condition is necessary except where the proviso applies. The opinion relies on this decision to support the proposition that the AO's subjective satisfaction (reason to believe) sufficed to confer jurisdiction to issue notice under Section 148/147. The Court (and the Tribunal before it) applied this formulation to the facts, finding material before the AO to constitute that 'reason to believe'.
DEPUTY CIT v. BEARDS SHELL LTD. (244 ITR 256) Principle: A provision for bad and doubtful debts that has not been written off in the profit & loss account does not represent an 'ascertained liability' and, therefore, ordinarily is liable to be included in book profit for tax computation purposes. The AO invoked this authority to treat the assessee's claimed provision for bad and doubtful debts (Rs. 3,14,37,439/-) as not representing an ascertained liability, and thus includible in book profit under Section 115JA. The opinion reproduces this application and records the AO's reliance on the precedent.

Court's Reasoning and Analysis

The opinion records a sequence of legal analysis and reproduced reasoning from earlier fora (AO and ITAT) and relies on apex-court authority to resolve the jurisdictional issue. The court's analytical pathway as set out in the text is as follows:

  1. Identification of the central jurisdictional question: whether a notice under Section 148 can be issued when proceedings arising from a notice under Section 143(2) are pending consideration. The Court framed this as the substantial question of law for admission.
  2. Recounting of the factual matrix: timelines of the original and revised returns, dates when processing and orders were passed, date of issue of Section 148 notice (23.12.2003), and the issuance of Section 143(2) hearing notice (16.12.2004). The chronology was used to examine whether proceedings under Section 143(2) remained pending at the time of issuing Section 148 or whether the time for completing assessment under Section 143(3) had expired.
  3. Consideration of precedent (Nizam's Trust): the Court records the assessee's reliance on the principle that reassessment cannot be initiated while the return-based proceedings remain pending. That principle was acknowledged in the opinion as a settled law proposition cited by the assessee.
  4. Consideration of the post-1989 statutory scheme and Rajesh Jhaveri: to 'fortify' the Revenue's contention, the Court (via the opinion) places reliance on the Supreme Court's exposition that following the substitution of Section 147, the existence of a 'reason to believe' (single condition) is sufficient for jurisdiction to reopen an assessment in the main provision (except where the proviso applies and both conditions must be satisfied).
  5. Application to facts: applying the Rajesh Jhaveri principle to the materials placed before the AO, the AO's stated reasons (incorrect computation under Section 115JA, the treatment of provision for bad debts, and royalty write-back) were held to constitute sufficient material to form a subjective 'reason to believe' that income had escaped assessment. The opinion explicitly records the conclusion that the AO had come to subjective satisfaction as indicated in his communications and therefore could validly initiate reassessment.
  6. On the merits aspects recorded by the AO and the Tribunal: the AO relied on Deputy CIT v. Beards Shell Ltd. to treat the unwritten-off provision for bad debts as not being an ascertained liability and hence includible in book profit. The royalty waiver, being the write-back of amounts previously debited to profit & loss, was treated as taxable income for the purpose of arriving at book profit under Section 115JA.
  7. The opinion reproduces the Tribunal's reasoning that (i) no proceedings were pending before the AO (the time for completion under Section 143(3) had expired), (ii) initiation of reassessment was valid, and (iii) on the merits, the AO's conclusions on book profit/bad debts/royalty were sustainable based on the materials and precedent.

Note: The opinion text extensively reproduces AO and ITAT reasoning and cites Supreme Court authority; the narrative above follows the sequence and content of reasoning as set out in the provided opinion text without addition or inference beyond those passages.

Holding and Implications

The provided extract does not contain a clearly labelled final pronouncement by this Court (for example, an explicit concluding paragraph stating the High Court's final order in terms such as "the appeal is dismissed" or "the appeal is allowed"). The text reproduces the ITAT's order (which concluded that the reassessment was valid and the ITAT dismissed the assessee's appeal before it, answering in favour of the Revenue), and records the issues and authorities considered by this Court.

Therefore:

  • This information was not available in the provided opinion.

If a final operative order of this Court were present in the document excerpt, it would be summarized here with the core ruling emphasized and immediate consequences for the parties set out. As that explicit concluding statement by the Court is not included in the provided text, no attempt has been made to state a final High Court disposition beyond what is quoted from the ITAT and earlier orders.

Document titles and citations are reproduced exactly as they appear in the provided opinion. No facts, holdings, or outcomes have been invented or inferred beyond the text supplied.

Show full summary ...

    M/S. Kone Elevator India Pvt. Ltd. v. The Income-Tax Officer, Company Circle-Ii (4), 121, Mahatma Gandhi Road, Chennai - 600 034.

    (Judgment was delivered by ELIPE DHARMA RAO, J.) The above Tax Case Appeal is filed against the order dated 15.10.2007 passed by the Income Tax Appellate Tribunal, Chennai Bench 'B' in I.T.A. No.1340 (MDS)/2006.

    2. The brief facts necessary for the disposal of the case are that the assessee-Company had filed its return of income for the assessment year 1998-1999 on 30.10.1998 admitting 'Nil' income, which was processed under Section 143(1)(a) of the Income-tax Act, 1959 (hereinafter referred to as "the Act") on 10.5.1999. Subsequently, the assessee filed a revised return on 26.11.1999 admitting 'Nil' income by enclosing some more TDS certificates that were omitted to be enclosed along with the original return of income, which were also processed on 29.3.2001. Again a revised order was passed on 27.6.2002 giving credit to some more TDS certificates which resulted in an additional refund of Rs.8,86,226/-.

    3. Thereafter, it was noticed that on a perusal of records, the assessee-Company had not computed the income under Section 115 JA of the Act properly. Therefore, on facts, there was a reason to believe that the income assessable to tax has escaped assessment. In view of the same, a proceeding under Section 147 of the Act was initiated by issuing notice under Section 148 of the Act on 23.12.2003. In response to the said notice, the assessee's representative M/s.N.C.Rajagopal & Co. Chartered Accountants vide their letter dated 5.1.2004 informed that the original return filed for the Assessment Year 1998-99 may be treated as the one filed in response to the notice issued under Section 148 of the Act. Further, notice for hearing under Section 143(2) of the Act was issued to the assessee on 16.12.2004. In response to this notice, Shri. R. Niranjan Chawala of M/s. N.C. Rajagopal & Co., Chartered Accountants appeared on behalf of the assessee.

    4. After hearing the representative of the assessee, the Assessing Officer has given his reasons for re-opening the assessment for the assessment Year 1998-99 as follows:-

    " (A) The assessee Company has not admitted income under section 115JA under the pretext of having unabsorbed depreciation and unabsorbed loss.

    (B) The provisions for bad and doubtful debts was omitted to be considered for arriving the book profit u/s. 115JA of the Act.

    (c) The assessee company has not credited the Royalty written back in the P & L A/c which were written back by the collaborator which is clearly a taxable income.

    Therefore, the aforesaid reasons are the basis leading to the conclusion that income otherwise taxable has escaped assessment and hence, the notice u/s. 148 has been issued to you for the A.Y. 1998-99."

    5. The Assessing Officer, on a consideration of the facts and circumstances of the case, held that as per Section 115JA, the assessee did not have any business loss or unabsorbed depreciation to be carried out to Assessment Year 1998-99. Further, the assessee claims that provision for bad and doubtful debts amounting to Rs.3,14,37,439/- is an ascertained liability and hence this is not liable for inclusion in book profit for the purpose of Section 115JA. However, as per the decision of this Court in the case of DEPUTY CIT v. BEARDS SHELL LTD. reported in 244 ITR 256, provision for bad and doubtful debts not written off in the Profit and Loss Account does not represent 'ascertained liability' and this is certainly liable for inclusion in book profit. But for such a claim which is not an ascertained liability the book profit would have been higher. By resorting to such claim, the assessee has clearly tried to suppress its income.

    6. Further, the assessee has claimed that an accumulated royalty of Rs.2,61,18,013/- which was debited in the P & L account for the Assessment Years 1991-92 to 1997-98 was written back to the P & L Account for this assessment year since the royalty was waived by their Collaborator M/s. Kone OY Finland. The assessee considered this royalty written back in the 'P & L Account Appropriation Account', instead of crediting the same in the P & L Account. Since the royalty had been debited to P & L Account from the accounting year ending 31.3.1991 onwards, the waiver of royalty is clearly a taxable income and has to be treated as income and the book profit u/s. 115JA of the Act has to be arrived at accordingly.

    7. As against the said order, the assessee filed an appeal before the Commissioner of Income-tax (Appeals)-III and the said appeal was allowed by an order dated 17.2.2006, holding as follows:-

    " I have considered the various submissions made by the appellant's representative both on the issue of jurisdiction and on merits. After going through the documents furnished in support of the facts that a valid notice u/s 143(2) has been issued within the time limit permitted under the Act and allowing the proceedings to remain inconclusive, the Assessing Officer does not get jurisdiction to initiate action u/s. 148 of the Act as held by the apex court in the two cases relied on by the appellant. I, therefore, hold that the assessment has not been validly reopened and hence the impugned order passed is ab initio void. In as much as the reassessment proceedings have been struck down as not valid in law, other grounds of appeal are not considered. The appellant succeeds on this ground."

    8. As against the said order, the Department filed an appeal before the Income Tax Appellate Tribunal and the Tribunal, by its order dated 15.10.2007, reversed the findings of the Commissioner of Income Tax (Appeals)-III, holding as under:-

    " We have heard the rival submissions. The Commissioner (Appeals) quashed the assessment order on the ground that the Assessing Officer issued notice under section 143(2) within the time permitted under the Act and allowed the proceedings to remain inconclusive. According to the Commissioner (Appeals) under such circumstances the Assessing Officer cannot assume jurisdiction to initiate action under section 148 of the Act. It was made clear before us that the time for completing the assessment under section 143(3) did expire. No proceedings in this regard were pending before the Assessing Officer. As such there was no error in the issuance of notice under section 148. We have taken into consideration the entire conspectus of the case. In our opinion the Commissioner (Appeals) was not correct in quashing the assessment on the ground that the proceedings pursuant to the notice under section 143(2) were inconclusive. Since no proceedings were pending in this regard we hold that the initiation of the reassessment proceedings was valid under the law. Accordingly we set aside the impugned order and restore the issue to the file of the Commissioner (Appeals) with a direction to decide the issue afresh."

    As against the said order, the assessee has filed the present tax case appeal.

    9. While admitting the appeal, this Court formulated the following substantial question of law:-

    " Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal is right in law in holding that the issuance of notice under Section 148 of the Income-tax Act is valid in law when notice issued under Section 143(2) is pending consideration?"

    10. Learned counsel appearing for the assessee submitted that the Income-tax Appellate Tribunal erred in holding that the proceeding under Section 148 of the Act has been validly initiated and that the assessment is not liable to be annulled on the ground of lack of jurisdiction.

    11. The learned counsel also submitted that the Income Tax Appellate Tribunal failed to notice that the jurisdiction under Section 147 of the Act can be invoked only if the proceedings under Section 143 (2) of the Act has resulted in an assessment or in the alternative, proceedings for enquiry under Section 143(2) of the Act has not been initiated by issuing notice. Once a notice under Section 143(2) is issued, proceedings under Section 147 of the Act cannot be initiated, so long as the said notice has not fructified in an order under Section 143(3) of the Act.

    12. Learned counsel further submitted that the Income Tax Appellate Tribunal erred in holding that since the time for completing the assessment under Section 143(3) of the Act had expired after issuing notice under Section 143(2) of the Act, proceedings under Section 147 of the Act could be initiated.

    13. In support of her submissions, the learned counsel relied on the decision of the Hon'ble Supreme Court reported in the case of TRUSTEES OF H.E.H. NIZAM'S TRUST v. C.I.T. ((2000) VOL. 242 I.T.R. 381), wherein the Hon'ble Supreme Court has held as under:-

    " It is settled law that unless the return of income already filed is disposed of, notice for reassessment under Section 148 of the Income-tax Act, 1961, cannot be issued, i.e. no reassessment proceedings can be initiated so long as assessment proceedings pending on the basis of the return already filed are not terminated. A return of income filed in the form prescribed along with an application for return under section 237 of the Act is a valid return. Filing of return in the form prescribed under section 139 of the Act along with the application for refund is not an empty formality. It assumes importance if such return had not been filed earlier."

    In the instant case, for the Assessment Year 1998-99 the assessee filed its return of income on 30.10.1998 which was processed under Section 143(1)(a) of the Act on 10.5.1999. The assessee filed its revised return of income on 26.11.1999, which was also processed on 29.3.2001 and final order was passed on 27.6.2002. Thereafter, on a perusal of records, it was noticed that the assessee-Company has not computed the income under Section 115 JA of the Act properly. Therefore, on facts, there was a reason to believe that the income assessable to tax has escaped assessment. In view of the same, proceedings under Section 147 of the Act was initiated by issue of notice under Section 148 of the Act on 23.12.2003, which is within the prescribed time limit.

    14. To fortify the aforesaid contention, in the decision reported in the case of ASSISTANT COMMISSIONER OF INCOME-TAX v. RAJESH JHAVERI STOCK BROKERS P. LTD. ((2007) 291 ITS 500), the Hon'ble Supreme Court has held in paragraph 17 as under:-

    " The scope and effect of section 147 as substituted with effect from April 1, 1989, as also sections 148 to 152 are substantially different from the provisions as they stood prior to such substitution. Under the old provisions of section 147, separate clauses (a) and (b) laid down the circumstances under which income escaping assessment for the past assessment years could be assessed or reassessed. To confer jurisdiction under section 147(a) two conditions were required to be satisfied: firstly the Assessing Officer must have reason to believe that income, profits or gains chargeable to income tax have escaped assessment, and secondly he must also have reason to believe that such escapement has occurred by reason of either omission or failure on the part of the assessee to disclose fully or truly all material facts necessary for his assessment of that year. Both these conditions were conditions precedent to be satisfied before the Assessing Officer could have jurisdiction to issue notice under section 148 read with section 147(a). But under the substituted section 147 existence of only the first condition suffices. In other words if the Assessing Officer for whatever reason has reason to believe that income has escaped assessment it confers jurisdiction to reopen the assessment. It is, however, to be noted that both the conditions must be fulfilled if the case falls within the ambit of the proviso to section 147. The case at hand is covered by the main provision and not the proviso."
    " 15. Therefore, applying the aforesaid ruling of the Apex Court to the facts and circumstances of the case, the Assessing Officer came to the subjective satisfaction as indicated in his letter dated 7.2.2005 referred to above. Therefore, it cannot be stated that the contention of the learned counsel for the appellant that the Assessing Officer has no jurisdiction to reconsider the matter or to initiate reassessment proceedings once the proceedings are concluded. As laid down by the Supreme Court, the condition precedent is that the Assessing Officer must have reason to believe that income, profits or gains chargeable to income tax have escaped assessment. As could be seen from the assessment order, it is seen that as per Section 115JA of the Act, the assessee did not have any business loss/unabsorbed depreciation to be carried out to Assessment Year 1998-99."
    " 16. With regard to inclusion of book profit, the assessee claims that the provision for bad and doubtful debts amounting to Rs.3,14,37,439/- is an ascertained liability and hence this is not liable for inclusion in book profit for the purpose of Section 115JA of the Act. But, according to the Assessing Officer, as per the decision of this Court in the case of DEPUTY CIT v. BEARDS SHELL LTD. reported in 244 ITR 256, provision for bad and doubtful debts not written off in the Profit and Loss Account does not represent 'ascertained liability' and this is certainly liable for inclusion in book profit. But for such a claim which is not an ascertained liability the book profit would have been higher by this amount. By resorting to such a claim, the assessee has clearly tried to suppress its income."
    " 17. With regard to the claim of accumulated royalty, the assessee has claimed that accumulated royalty of Rs.2,61,18,013/- which was debited in the P & L account for the assessment years 1991-92 to 1997-98 was written back to the P & L Account for this assessment year since the royalty was waived by their Collaborator M/s. Kone OY Finland. The assessee considered this royalty written back in the 'P & L Account Appropiration Account'. Instead of crediting the same in the P & L Account, since the royalty had been debited to P & L Account from the accounting year ending 31.3.1991 onwards, the waiver of royalty is clearly a taxable income and has to be treated as income and the book profit u/s. 115JA of the Act arrived accordingly."
    " 18. Considering the above reasons given by the Assessing Officer, we consider it appropriate to hold that it is not proper to accept the contention of the learned counsel for the assessee that there is no material before the Assessing Officer for coming to the subjective satisfaction that he has reason to believe that certain income assessable to tax has escaped assessment for the Assessment Year 1998-99."
    " 19. As per the decision of the Hon'ble Supreme Court, once the Assessing Officer has come to the conclusion that the taxable amount has escaped assessment, two conditions were required to be satisfied on the basis of the materials placed before him. Both these conditions were conditions precedent to be satisfied before the Assessing Officer could have jurisdiction to issue notice under section 148 read with section 147(a). But under the substituted section 147 existence of the first condition alone is suffice. In other words if the Assessing Officer has reason to believe that certain income assessable to tax has escaped assessment it confers jurisdiction to reopen the assessment. It is, however, to be noted that both the conditions must be fulfilled if the case falls within the ambit of the proviso to section 147. Hence, we are not able to appreciate the contention of the learned counsel for the appellant that the Assessing Officer has no jurisdiction to reopen the assessment."
    " 20. The finding of the Assessing Officer is that as per Section 115JA, the assessee did not have any business loss or unabsorbed depreciation to be carried out to Assessment Year 1998-99. Further, the assessee has claimed that an accumulated royalty of Rs.2,61,18,013/- which was debited in the P & L account for the Assessment Years 1991-92 to 1997-98 was written back to the P & L Account for this assessment year since the royalty was waived by their Collaborator M/s. Kone OY Finland. The assessee considered this royalty written back in the 'P & L Account Appropriation Account', instead of crediting the same in the P & L Account. Since the royalty had been debited to P & L Account from the accounting year ending 31.3.1991 onwards, the waiver of royalty is clearly a taxable income and has to be treated as income and the book profit u/s. 115JA of the Act has to be arrived at accordingly. In the facts and circumstances of the case, the Assessing Officer has rightly assessed the matter and passed the assessment order. In such circumstances, the tax case appeal stands dismissed. We answer against the assessee and in favour of the Revenue."

    ssa.

    To The Income-tax Officer, Company Circle-II (4), 121, Mahatma Gandhi Road, Chennai 600 034

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    M/S. Kone Elevator I... v. The Income-Tax Offic...
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