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Advocates
  • Mr. T.C.A Ramanujam
  • Mr. T.R Senthil Kumar Mr. A.P Srinivas Standing counsel for Income Tax
Judges
  • Hon'ble Tmt.Justice Chitra Venkataraman
  • Hon'ble Thiru.Justice T.S. Sivagnanam
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Citation Codes
Equivalent Citations
citation codes
Case Number
Advocates
  • Mr. T.C.A Ramanujam
  • Mr. T.R Senthil Kumar Mr. A.P Srinivas Standing counsel for Income Tax
Judges
  • Hon'ble Tmt.Justice Chitra Venkataraman
  • Hon'ble Thiru.Justice T.S. Sivagnanam
Acts
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Smart Summary

Structured Summary of the Opinion (Chitra Venkataraman, J.)

Factual and Procedural Background

The assessee is a sole proprietor carrying on business as M/s. Rekha Silk Industries and resided at 64, Godown Street, Madras-1. On 31 August 1995 a search under Section 132 was conducted at the premises of Shri Sridhar Sarada and Shri Ramachandran Sarada (two other persons who shared the same address). Materials recovered during that search contained documents relating to several transactions in stock and shares attributable to the assessee.

Based on those materials the Revenue issued a notice under Section 158BC(a) on 5 December 1995 calling for returns for the block period. The assessee replied on 23 December 1995 requesting time to enable auditors/chartered accountants to prepare returns. The Assessing Officer thereafter sought further particulars and the assessee filed returns and replied through its Chartered Accountant in August 1996. An assessment was framed on 26 August 1996 under Section 143(3) read with Section 158BC (block assessment procedure).

The assessee appealed to the Income Tax Appellate Tribunal (ITAT). The ITAT initially set aside the assessment (12.4.1999) holding that there had been no search in the assessee's name and therefore Section 158BC could not be applied. The Revenue appealed to this Court (T.C.(A) No.241 of 2000). By order dated 9.12.2003 this Court set aside the Tribunal's order and remanded the matter to the Tribunal for fresh consideration, holding that the Tribunal had not applied its mind to the specific facts of the assessee and had merely followed another group's order.

On remand the Tribunal again set aside the assessment and remitted the matter to the Assessing Officer for de novo consideration on 15.12.2004, observing that appropriate material was not on record to justify the additions. The assessee then filed the present appeal to challenge the Tribunal's second order, raising several substantial questions of law and seeking to impugn the jurisdiction and reasoning of the Tribunal and of the assessing process.

Legal Issues Presented

  1. Whether the Tribunal was justified in rejecting the objection to the Assessing Officer's jurisdiction under Chapter XIV-B (Section 158BC) when there was allegedly no search under Section 132 in the name of the assessee.
  2. Whether the Tribunal erred in not following its earlier decisions in 41 other cases arising from the same search when facts and law were said to be identical.
  3. Whether the Tribunal was justified in remitting the matter to the Assessing Officer ignoring the High Court's earlier orders and despite submissions claiming absence of material indicating undisclosed income.
  4. Whether the Tribunal overlooked the fact that the Assessing Officer never recorded any satisfaction regarding books or documents indicating undisclosed income when no search warrant was in the assessee's name.
  5. Whether the Tribunal failed to consider materials placed before it that, according to the assessee, showed the additions were unwarranted.
  6. Whether the Tribunal improperly ignored that the Department accepted the Tribunal's decision in 41 other similar cases when reference applications under Section 256(1) were rejected.

Arguments of the Parties

Appellant's (Assessee's) Arguments

  • The assessee contended that there was no search conducted in its name and no search warrant issued against it; therefore an assessment under Section 158BC was without jurisdiction.
  • It was argued that the Tribunal originally annulled the block assessment and should have cancelled it rather than remanding, because appropriate materials were not on record to show undisclosed income.
  • The assessee asserted the Tribunal was inconsistent in remanding the matter when in 41 other cases arising from the same search the Tribunal had set aside assessments, and the Department had accepted those outcomes.
  • The assessee relied on the Supreme Court decision in Manish Maheswari v. Asst. Commissioner of Income Tax (2007) 289 ITR 341 (SC) to support the proposition that where no search/warrant exists in the assessee's name, Section 158BC cannot be invoked.

Respondent's (Revenue's) Arguments

  • The Revenue's case was that there was no contention that the search was conducted in the name of the assessee; rather the assessment proceeded on the basis of materials seized during a search of two other persons residing at the same address.
  • The Revenue maintained that the assessment was properly made under Section 158BD (which permits block assessment of other persons where seized documents indicate undisclosed income of such other persons), and hence the absence of a search warrant in the assessee's name was not fatal.
  • The Revenue pointed out that individual documents relating to the assessee were seized during the search on 31.8.1995 at the premises and that those materials formed the basis for initiating proceedings against the assessee.
  • The Revenue produced the assessment records in court to establish the factual foundations for the block assessment and the assessee's awareness of the notice and proceedings (including the assessee's 23.12.1995 letter).

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Manish Maheswari v. Asst. Commissioner of Income Tax, (2007) 289 ITR 341 (SC) The Apex Court articulated the conditions precedent for invoking Section 158BD: (i) the Assessing Officer must record satisfaction that undisclosed income belongs to a person other than the person searched under Section 132; (ii) seized books/documents/assets must be handed over to the Assessing Officer having jurisdiction over that other person; and (iii) proceedings under Section 158BC must be initiated against that person. Where these conditions are absent (no recorded satisfaction, no handing over, and no proceedings under Section 158BC), the assessment is vitiated for want of jurisdiction. The Court considered the Manish Maheswari decision, examined its facts, and concluded it was distinguishable. In Manish the mandatory satisfaction was not recorded and documents were not handed over; here the records showed seizure of materials pertaining to the assessee, notice was issued and the assessee participated in the proceedings. Therefore the Court found Manish inapplicable to the facts before it.
Commissioner of Income Tax (Appeals) v. Indore Constructions, (2005) 279 ITR 545 (M.P. High Court) This Madhya Pradesh High Court decision was relied upon by the Tribunal in earlier proceedings (as noted by the Tribunal). The Court observed that the Tribunal had referred to this decision, but noted that it was reversed by the Supreme Court (in the Manish Maheswari decision). The High Court therefore treated the MP decision as of limited relevance to the present facts and proceeded to distinguish the Supreme Court's reasoning in Manish from the facts here.

Court's Reasoning and Analysis

The Court proceeded by examining the documentary record and the assessment file produced by the Revenue to resolve the disputed factual questions (notably whether there had been a search in the assessee's name and whether materials relevant to the assessee were seized). The analysis followed these steps:

  1. Fact-finding from records: The Court extracted material from the assessment record and found that a search under Section 132 was conducted on 31.8.1995 at the premises of Shri Sridhar Sarada and Shri Ramachandran Sarada, at an address where the assessee also resided. The search yielded documents showing transactions in stocks and shares attributable to the assessee.
  2. Notice and participation: The Court noted the notice under Section 158BC(a) dated 5.12.1995, the assessee's written response on 23.12.1995 (requesting time and acknowledging the notice), the subsequent correspondence and filings by the assessee's Chartered Accountant in August 1996, and the eventual assessment framed on 26.8.1996. These facts indicated the assessee was aware of and participated in the block assessment proceedings.
  3. Legal framework for block assessment: The Court analysed the relationship between Section 158BC (procedure for block assessment) and Section 158BD (application of block assessment to persons other than the one searched). It observed that Chapter XIV-B is the exclusive regime for block assessments; references to Section 158BC in the assessment process do not convert or negate the applicability of Section 158BD where the facts show materials seized in the course of a search relate to another person.
  4. Distinguishing authority relied upon by the assessee: The Court examined the Supreme Court's decision in Manish Maheswari which invalidated an assessment because the Assessing Officer had not recorded satisfaction required under Section 158BD, documents had not been handed over to the relevant Assessing Officer, and no proceedings under Section 158BC had been initiated. The Court emphasised that those specific factual defects were not present in the instant case: here, materials relating to the assessee were seized, notice under Chapter XIV-B was issued, the assessee filed returns and participated, and the assessment was framed.
  5. Conclusion on jurisdiction: Given the record evidence of seizure of the assessee's documents, the assessee's awareness and active participation in proceedings, and the fact that Chapter XIV-B procedure was followed, the Court concluded there was no valid ground to accept the assessee's jurisdictional challenge that the block assessment was bad in law.
  6. On remand vs. cancellation: The Court agreed with the Tribunal's approach to remit the matter to the Assessing Officer for adjudication on merits since the Tribunal had found that appropriate materials were not on record to adjudicate certain claims; the Court found the remand appropriate in the factual matrix rather than directing outright cancellation.

Holding and Implications

Holding:

DISMISSED — The Tax Case (Appeal) filed by the assessee was dismissed. The Court confirmed the Tribunal's order remitting the matter to the Assessing Officer for de novo adjudication on the merits. The miscellaneous petition (M.P. No.1 of 2006) was also dismissed. The Court ordered the Assessing Officer to expedite the assessment without further delay. The Court ordered no costs.

Implications:

  • The direct consequence is that the reassessment proceedings remain alive: the matter is remitted to the Assessing Officer to proceed on merits in accordance with law and the directions of the Tribunal and this Court.
  • The Court rejected the assessee's submission that the block assessment was void for lack of jurisdiction where the search warrant was not in the assessee's name, on the facts of this case — because documents relating to the assessee were in fact seized and the assessee participated in the Chapter XIV-B process.
  • The opinion distinguishes the Supreme Court authority relied upon by the assessee (Manish Maheswari) on factual grounds and does not purport to lay down a new general proposition of law; it applies existing statutory principles to the record before it. Accordingly, no new legal precedent is announced beyond this application to the present facts.

Notes: This summary is based exclusively on the content of the provided opinion and does not introduce facts or conclusions beyond those expressly contained in that opinion.

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    Sri Kailash Sarda 64, Godown Street, Chennai-600 001 v. Commissioner Of Income Tax Viii Chennai

    JUDGMENT

    (CHITRA VENKATARAMAN, J.)

    The assessee herein carries on business as a proprietor in the name and style of M/s. Rekha Silk Industries. It is seen from the facts narrated in the orders of the Assessing Officer that there was a search operation on 31.8.1995 in the premises of Shri. Sridhar Sarada and Shri. Ramachandran Sarada. The search operation resulted in recovery of materials relating to several transactions in stock and shares. Incidentally, the assessee is also residing in the same premises, namely, 64, Godown Street, Madras - 1, where the search was conducted. Based on the materials recovered pertaining to the assessee, notice under Section 158BC(a) of the Income Tax Act was sent to the assessee on 05.12.2005 calling upon the assessee to file income tax returns within 15 days from the date of service of notice. In response to that notice, the assessee filed a letter on 23rd December, 1995 stating that the papers relating to the search to the extent available were being looked into by his Auditors M/s. B.M Kumbhat & Co., Madras; that it would take at least one month for them to go into the books and prepare the return of income by the Chartered Accountant. In the circumstances, the assessee pleaded time to file returns for the block period by 15th January, 1996. Subsequent to that, by proceedings dated 17.7.1996, the Income Tax Officer directed the assessee to produce certain documents pertaining to the details found in the materials as to the purchase of shares in the last ten years giving the details of the shares purchased, cost of purchase, dealer's name, cost of construction of building constructed by the company during the last ten years and such other particulars relevant to the business of the assessee.

    2. It is seen from the files produced before this Court by the Revenue that the assessee filed returns, based on which the Assessing Officer sent a notice on 12.8.1996 insisting on particulars called for, to be furnished immediately. In response to the details called for, the assessee's Chartered Accountant filed reply on 9 August, 1996 and 20 August, 1996. Based on the details thus furnished by the assessee, ultimately, the assessment was made on the assessee on 26 August, 1996 under Section 143(3) read with Section 158BC of the Income Tax Act.

    3. The assessment order clearly pointed out that the search operation was made on 31.8.1995 in the premises of Shri. Sridhar Sarada and Shri. Ramachandra Sarada and that the details gathered therein revealed several transactions in stock and shares by the assessee. After considering the objections of the assessee, the assessment order was thus finalised and a demand was made. Aggrieved by this, the assessee went on appeal before the Income Tax Appellate Tribunal as per the provisions as it stood then.

    4. We find from the records placed before this Court that the assessment challenged in the appeal before the Income Tax Appellate Tribunal was considered by the Income Tax Appellate Tribunal under a common order pertaining to several of the family members' appeals also. The Tribunal passed the order on 12.4.1999 following the order passed in other group case and held that when there was no search in the premises of the assessee, the question of making an assessment under Section 158BC of the Income Tax Act did not arise. Thus the Tribunal allowed the appeal and set aside the assessment. Aggrieved by this, the Revenue came on appeal before this Court in T.C (A) No. 241 of 2000. By order dated 09.12.2003, this Court considered the appeal of the Revenue as against the present assessee along with another assessee of the group case and set aside the order of the Tribunal and remanded the matter back to the Tribunal for fresh consideration. This Court pointed out to the order of the Tribunal placing reliance on a specific finding that there was no search in the premises of the assessee and held that the Tribunal had merely followed the order passed in certain other assessees's cases forming part of the same family group. This Court noted the submission made by the Revenue that the block assessment made in the assessee's case was on the basis of the materials gathered at the time of search operation in the premises of the other assessee in the group case. Thus, this Court held that the Tribunal had not applied its mind to the facts of the case of the assessees before us and in order to appreciate the facts pertaining to the case, this Court set aside the order of the Tribunal and thus restored it back to the Tribunal for de novo consideration.

    5. Pursuant to the orders thus made in the Tax Case (Appeal), the Tribunal passed an order once again in the assessee's case on 15.12.2004 pointing out to the contention of the assessee that the block period assessment was reappraisal of the facts or change of opinion from the original assessment order and that the additions were mere estimates and not based upon any material found in the search. Since appropriate materials were not on record for adjudication, the Tribunal set aside the order of assessment and remanded the matter back to the Assessing Officer to consider the issues raised by the assessee on various aspects after giving adequate opportunity to the assessee.

    6. We find in paragraph 2 of the order of the Tribunal that there is a specific reference to the fact that there was a search and seizure operation under Section 132 of the Income Tax Act on 31.3.1995 in the premises of Shri Sridhar Sarada and Shri Ramachandran Sarada. Details relating to several transactions in stock and shares committed by the assessee were detected and based on the information pertaining to the assessee found in the course of the search, notice under Section 158BC(a) was sent to the assessee.

    7. Aggrieved by the said order of the Tribunal, the present appeal has been filed at the instance of the assessee on the following substantial questions of law:

    1. Whether the Tribunal is justified in rejected the objection to the assumption of jurisdiction by the Assessing Officer under Chapter XIV B when there was no search under Section 132 of the Income Tax Act in the name of the appellant petitioner?

    2. Whether the Tribunal is justified in law in not following its own earlier orders in 41 other cases arising from the same search on the same day when the facts and questions of law were identical?

    3. Whether the Tribunal is justified in remitting the matter to the assessing officer ignoring the orders of the High Court when detailed submissions were made to prove that there was no material to indicate undisclosed income before the Tribunal?

    4. Whether the Tribunal was justified in overlooking the fact that the Assessing Officer never recorded any satisfaction about the books of accounts and other documents indicating undisclosed income of the appellant petitioner when there is no search warrant against him?

    5. Whether in the facts and circumstances of the case the order of the Hon'ble Tribunal is sustainable in law in as much as the Tribunal overlooked the materials placed before it in support of the contention that the additions are unwarranted, without referring to any of those materials?

    6. Whether the Tribunal was justified in law in ignoring the fact that the department itself has accepted the decision of the Hon'ble Tribunal on rejection of reference application filed u/s.256(1) of the Act in 41 other cases where similar question of law was sought to be referred to the High Court for its opinion?”

    8. Learned counsel appearing for the assessee contended that when the consistent case of the assessee was that there was no search operation in the premises of the assessee and that the search warrant not being in the name of the assessee, the assessment made under Section 158BC of the Income Tax Act was totally without jurisdiction. He pointed out that the grounds raised before this Court at the first round of litigation was as to whether the Tribunal was right in annuling the block assessment made under Section 158 BC of the Income Tax Act and that the Department never highlighted the fact that the proceedings were meant to be under Section 158BD of the Income Tax Act. Learned counsel further pointed out that when the Tribunal had found that appropriate materials were not there on record to show any search operation in the name of the assessee, it ought to have cancelled the block assessment instead of remanding the matter back to the Assessing Officer. In effect, his submission is that the Tribunal should have followed its earlier order, which, in fact, was set aside by the High Court and that in at least 41 other cases arising from the same search on the same day, the Tribunal set aside the assessments. Consequently, according to the learned counsel, the Tribunal is inconsistent in its decision of remanding the matter by not following its own earlier orders in 41 other cases.

    9. Learned counsel made a particular reference to the decision of the Madhya Pradesh High Court reported in (2005) 279 ITR 545 (Commissioner of Income Tax (Appeals) v. Indore Constructions), referred to by the Tribunal, which was reversed by the Supreme Court in the decision reported in (2007) 289 ITR 341 (SC) (Manish Maheswari v. Asst. Commissioner of Income tax) and submitted that when on facts there was no search in the premises of the assessee and no warrant was made in the name of the assessee, the question of making assessment under Section 158BC of the Income Tax Act did not arise.

    10. Learned standing counsel appearing for the Revenue, however, pointed out that it was never the case of the Revenue that the search was on the assessee and that the assessment itself was based only on the materials gathered in the course of the search conducted in two other assessees's case residing in the same address as that of the assessee. The assessment, in effect, is only under Section 158BD of the Income Tax Act; consequently, no issue can be raised by the assessee about the non-service of search warrant. He also drew our attention to the grounds raised in the tax case in the earlier round of litigation that there were individual documents in the form of books and materials pertaining to the assessee seized in the course of search operation on 31.8.1995 in the premises of Shri. Sridhar Sarada and Shri. Ramachandran Sarada at 64, Godown Street, Madras-1, which led to the assessment on the assessee under Section 158BD of the Income Tax Act.

    11. Heard learned counsel appearing for the assessee, learned Standing Counsel appearing for the Revenue and perused the materials placed before this Court.

    12. Since the issue as to whether there was a search in the premises of the assessee and the search warrant was made in the name of the assessee were raised and were very much in dispute, to ascertain the facts, we called for the records from the Department and accordingly, learned Standing Counsel appearing for the Revenue has produced the assessment records before this Court.

    13. As may be seen from the narration of facts in the preceding paragraphs culled out from the files and from the assessment order, it is clear that the assessment was made consequent on the seizure of materials in the course of search operation under Section 132 of the Income Tax Act on 31.8.1995 in the premises of Shri. Sridhar Sarada and Shri. Ramachandran Sarada at 64, Godown Street, Madras - 1, where the assessee was also residing. The search operation resulted in seizure of various documents pertaining to the assessee's transactions too. Thus, taking note of the information pertaining to the assessee, proceedings were initiated by the Revenue by calling for particulars as well as to file returns for the block year. The letter written by the assessee on 23 December, 1995 makes no secret of the fact that notice was issued on 05.12.2995 calling upon the assessee to file returns within 15 days from the date of service of notice on block assessment proposed consequent on the seizure of materials in the course of search operation on other two persons. Thus the assessee is clear in his understanding of the provisions, under which the block assessment was made and was quite aware of the fact that the assessment under Chapter XIVB was as a result of seizure of materials in the course of search operation in the premises, where the assessee lived along with two other persons on whom the search warrant was issued. In the light of the above said fact, we do not find any justifiable ground to accept the plea of the assessee that the assessment made is bad in law.

    14. As far as the contention of the assessee that the assessment made under Section 158BC of the Income Tax Act is bad in law, we find that Section 158BC lays down the procedure for block assessment. The fact that the assessment is made based on the materials seized in the course of the search operation of two other persons, does not, mean that the assessment is not under Section 158BD of the Income Tax Act. As pointed out earlier, since the procedure given under Section 158BC is the only procedure given under Chapter XIV-B for making block assessment, the reference to Section 143(3) notice read with proceedings under Section 158BC does not make the assessment as the one not falling under Section 158BD. We may note herein that to make things abundantly clearly, the reference to Section 158BC was specifically inserted under Section 158BD under Finance Act, 2002, with effect from 01.06.2002 But even without this insertion, it is clear that if the Officer has to proceed for block assessment, the only chapter that would apply in a given set of circumstances for block assessment is Chapter XIV B. Thus, as per the procedure laid down under Section 158BC there is no confusion in the mind of the Officer as to the provision it is proceeded against nor in the mind of the assessee that the assessment was made consequent on the seizure of materials in the course of search operation in the premises of Shri. Sridhar Sarada and Shri. Ramachandran Sarada.

    15. In the light of the above-said fact and as evident from the documents available in the assessment records as well as in the assessment order itself, we have no hesitation in rejecting the contention made by the assessee that the block assessment fails in this case for want of jurisdiction.

    16. As regards the reliance placed on the decision reported in (2007) 289 ITR 341 (SC) (Manish Maheswari v. Asst. Commissioner of Income tax), a reading of the judgment of the Apex Court shows that a search operation was conducted under Section 132 of the Income Tax Act in the premises of one Shri. Maheswari, who apart from being a director of the company, is also a tax consultant. Several incriminating documents pertaining to the business of the company were seized. Based on that, proceedings were initiated against the assessee Maheswari. On appeal against the said order of assessment made under Section 158BC, the Tribunal held that the Assessing Officer had no jurisdiction to proceed against the assessee for making block assessments in terms of Chapter XIV-B, since there was no search conducted in terms of Section 132 of the Act. On appeal, the High Court held that the Assessing Officer had requisite jurisdiction in terms of Section 158BD of the Act read with Section 2(31) thereof.

    17. In considering the scope of Section 158BC and 158BD, the Apex Court pointed out as follows:

    “11. The condition precedent for invoking a block assessment is that a search has been conducted under section 132, or documents or assets have been requisitioned under section 132A. The said provision would apply in the case of any person in respect of whom search has been carried out under section 132A or documents or assets have been requisitioned under section 132A. Section 158BD, however, provides for taking recourse to a block assessment in terms of section 158BC in respect of any other person, the conditions precedent wherefor are: (i) satisfaction must be recorded by the Assessing Officer that any undisclosed income belongs to any person, other than the person with respect to whom search was made under section 132 of the Act; (ii) the books of account or other documents or assets seized or requisitioned had been handed over to the Assessing Officer having jurisdiction over such other person; and (iii) the Assessing Officer has proceeded under section 158BC against such other person. The conditions precedent for invoking the provisions of section 158BD, thus, are required to be satisfied before the provisions of the said Chapter are applied in relation to any person other than the person whose premises had been searched or whose documents and other assets had been requisitioned under section 132A of the Act.

    18. The Apex Court also pointed out that the only question that arise for consideration before the Court was as to whether the notice dated 6 February, 1996 satisfied the requirement under Section 158BD and the said notice did not record any satisfaction on the part of the Assessing Officer. Documents and other assets recovered during search had not been handed over to the Assessing Officer having jurisdiction in the matter and no proceedings were initiated under Section 158BC. Thus, there was a patent non-application of mind. Noting the facts, the Apex Court pointed out that the Assessing Officer had not recorded his satisfaction, which is mandatory; nor had he transferred the case to the Assessing Officer having jurisdiction over the matter. Thus, the Apex Court held that the assessment made being devoid of jurisdiction, could not be sustained.

    19. The judgment of the Apex Court, rested on facts narrated above, has no relevance to the facts herein. As already pointed out in the preceding paragraphs, notice was issued to the assessee consequent on the seizure of materials indicating the assessee's transaction in shares. The assessee had responded to the notice and accordingly, by entering into correspondence even as early as 23.12.1995 filed its return, participated in the assessment proceedings and suffered an assessment. Thus, in the background of the facts noted above, the decision relied on is a distinguishable one and has no relevance to the facts of the case herein. In the circumstances, we have no hesitation in confirming the order of the Tribunal remanding the matter for adjudication on merits. Accordingly, the Tax Case (Appeal) stands dismissed. No costs. Consequently, M.P No. 1 of 2006 is also dismissed.

    20. Since the Tribunal remanded the matter to the Assessing Officer as early as 15.12.2004 and the Tax Case (Appeal) is of the year 2006, we direct the Assessing Officer to expedite the assessment at the earliest without any further delay in this regard.

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    Sri Kailash Sarda 64, Godown Street, Chennai-600 001 v. Commissioner Of Income Tax Viii Chennai
    (Feb 10, 2014)