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Judges
  • Y.R Meena
  • Malay Kumar Basu, JJ.
Acts
  • section 256(2) of the Income-tax Act, 1961,
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Citation Codes
Equivalent Citations
citation codes
Case Number
Judges
  • Y.R Meena
  • Malay Kumar Basu, JJ.
Acts
  • section 256(2) of the Income-tax Act, 1961,
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Smart Summary

Analytical Summary of the Opinion (Y.R. Meena, J.)

Factual and Procedural Background

The matter arises from an application under section 256(2) of the Income-tax Act, 1961, by which this Court directed the Tribunal to refer two questions (set out in the application) concerning the validity of an order passed by the Commissioner of Income-tax (under section 263 of the Act) for assessment years 1981–82 to 1985–86.

The assessee is a partnership firm engaged in construction equipment, building materials, electrical fittings, ownership and renting of immovable properties, real estate dealings and trading in shares and securities. Assessments for the years 1981–82 to 1985–86 were completed under section 143(3).

On scrutiny, the Commissioner of Income-tax considered the assessments to be erroneous and prejudicial to revenue on several grounds (including alleged under‑assessment of the price paid for leasehold land, alleged receipt of "on‑money" on sale of flats, incorrect estimation of demolition proceeds, inflated accounting entries on revaluation of leasehold property, and non‑verification of alleged loans). A show‑cause notice under section 263 was issued and, after hearings, the Commissioner directed the Assessing Officer to re‑examine or make additions in specific respects.

The assessee appealed to the Tribunal. The Tribunal examined the record, concluded that the Assessing Officer had made necessary enquiries (including monitoring by Commissioner (Investigation)/Commissioner (Vigilance)), found the Commissioner of Income-tax's findings (especially on on‑money and the alleged Rs. 24 lakh payment for leasehold land) to be baseless, and quashed the Commissioner’s order under section 263. The Tribunal also dealt with the merits of the issues and set out detailed findings (paras. 26–30 of the Tribunal decision as reproduced in the opinion).

This Court heard counsel, considered the record and the Tribunal's findings, and answered the referred questions in favour of the assessee and against the Revenue.

Legal Issues Presented

  1. Whether, on the facts and in the circumstances of the case, the Tribunal was correct in law in annulling the impugned order of the Commissioner of Income‑tax dated June 10, 1986, passed under section 263 of the Income‑tax Act, 1961?
  2. Whether the findings of the Tribunal leading to the conclusion that the order of the Commissioner of Income‑tax dated June 10, 1986, was not valid in law are unreasonable and perverse?

Arguments of the Parties

Revenue / Commissioner of Income‑tax (summary of the Commissioner's case)

  • The Commissioner contended that the assessment orders by the Assessing Officer were erroneous and prejudicial to the interests of Revenue on several grounds: (i) the price for the leasehold land was of the order of Rs. 24 lakhs although only Rs. 1 lakh deposit had been recorded; (ii) acquisition of leasehold rights over 21 cottahs for 75 years for a mere Rs. 1 lakh deposit; (iii) cost of construction was understated in accounts (assessed at Rs.100 or Rs.115 per sq. ft., whereas seized records indicated much higher costs); (iv) alleged receipt of "on‑money" on sale of flats; (v) incorrect estimation of proceeds from demolition of old building; (vi) crediting of partners' personal accounts on revaluation to the extent of Rs. 74,12,700 without corresponding wealth‑tax disclosures; and (vii) non‑verification of alleged loans.
  • After issuing a show‑cause notice and hearing, the Commissioner held specific points: (a) the price of land could be taken at Rs. 22,84,168; (b) on‑money to the tune of Rs. 1,02,45,000 had been received on sale of flats; and (c) Rs. 51,000 should be included towards sale proceeds of demolition material (the Assessing Officer had accepted Rs. 28,000).
  • Accordingly, the Commissioner directed the Assessing Officer to re‑examine construction costs, receipt of on‑money, add Rs. 23,000 (difference between Rs. 51,000 and Rs. 28,000) for demolition proceeds, and verify the loans claimed by the assessee.

Assessee (summary of the assessee's case)

  • The assessee argued there was no material before the Commissioner to estimate the cost of leasehold land at Rs. 22,84,168; the assessment orders had been passed after collection and consideration of relevant materials and were monitored by the Commissioner of Income‑tax (Investigation)/Commissioner (Vigilance).
  • The assessee disputed the Commissioner's on‑money theory as baseless, noting that materials relied upon (seized documents such as 'BM‑I') were not recovered from the assessee, were unsigned, did not identify the assessee or the property, and therefore could not support the Commissioner's conclusions.
  • With respect to demolition materials, the assessee explained that an earlier offer of Rs. 51,000 could not be accepted because a court stay prevented demolition at that time, the offer was withdrawn, and the material was ultimately sold for Rs. 28,000; thus there was no basis to treat the amount as Rs. 51,000.
  • The assessee maintained that loans (cash credits) had been verified by the Assessing Officer and supported by confirmations, and that construction costs were supported by vouchers and had been examined by the Assessing Officer.

Table of Precedents Cited

No precedents were cited in the provided opinion.

Court's Reasoning and Analysis

The Court's analysis followed the record and the Tribunal's detailed findings. The key points of reasoning, as reflected in the opinion, are:

  1. Investigation and supervision: The Court examined whether the Assessing Officer had made a proper enquiry. It found the assessments were completed after multiple hearings (1982–85), with order sheets and reports on record. The Income‑tax Officer's enquiries were carried out under the directions and monitoring of the Commissioner of Income‑tax (Investigation)/Commissioner (Vigilance), including internal reports and discussions; thus the Court concluded the assessments were not completed without proper enquiry (para. 9 and para. 32).
  2. Lease payment allegation (Rs. 24 lakhs): The Court noted the lease deed was executed on February 3, 1979, and the relevant assessment year for that transaction was 1980–81, which lies outside the assessment years under consideration (1981–82 to 1985–86). The Commissioner relied on a seized document ('BM‑I') to infer a Rs. 24 lakh payment, but the Tribunal found that BM‑I was typed, unsigned, lacked identification of parties and property, and did not tally with the relevant covered area. The Deputy Director of Inspection had also stated there was no direct evidence of substantial on‑money payment from the vendor. On these bases, the Court concluded there was no material to support treating the lease payment as Rs. 24 lakhs for the assessment years in question (paras. 26, 33 and 10).
  3. On‑money allegations on sale of office space: The Commissioner relied on seized papers (BM‑1, A‑12, HS‑3 and SS‑3) to compute alleged on‑money receipts of Rs. 1,02,45,000 (and other figures). The Tribunal (and the Court) noted that these papers were not recovered from the assessee, were unsigned, did not name the assessee or the property, and did not establish who received the amounts. The Tribunal also pointed to confirmations filed by purchasers and income‑tax file numbers obtained by the Assessing Officer to certify genuine prices received. The Court accepted the Tribunal's conclusion that suspicion cannot substitute proof and that the on‑money theory lacked a reliable evidentiary foundation (paras. 27, 35–36).
  4. Proceeds from demolition material: The Commissioner proposed adding Rs. 23,000 (difference between an earlier offer of Rs. 51,000 and the actual sale of Rs. 28,000). The Tribunal and the Court found no basis for computing the value in that way because the earlier higher offer could not be accepted due to a court stay and was withdrawn; the material was ultimately sold for Rs. 28,000, which was reflected in accounts (paras. 28 and 33).
  5. Verification of loans and genuineness of cash credits: The Tribunal found, and the Court accepted, that loans taken by the assessee were verified during assessment proceedings and that confirmation letters of creditors were on record; therefore the Commissioner could not justifiably direct further verification (paras. 29 and 14).
  6. Cost of construction: The Assessing Officer examined construction costs across assessment years and accepted vouchers supporting direct and indirect expenditure (figures are set out in para. 11). The Court found that when expenditures are supported by vouchers and the assessments were monitored by the Commissioner (Vigilance), there was no justification to treat the Assessing Officer's findings as erroneous (paras. 11 and 34).
  7. Standard of review and conclusions: The Court repeatedly accepted the Tribunal's application of evidentiary standards — distinguishing suspicion from proof and requiring cogent material to set aside assessments under section 263. On the present record, the Court found that the Tribunal's findings were neither unreasonable nor perverse and that the assessments were not erroneous or prejudicial to revenue (paras. 6, 24, 36–37).

Holding and Implications

Holding:

The Court answered Question No. 1 in the affirmative (in favour of the assessee and against the Revenue) and Question No. 2 in the negative (also in favour of the assessee and against the Revenue).

In practical terms, the Court upheld the Tribunal's quashing of the Commissioner of Income‑tax's order under section 263: the Court found no valid basis in the record to treat the assessment orders as erroneous and prejudicial to the interests of the Revenue.

Implications:

  • Direct effect: The decision affirms the Tribunal's conclusion that the assessments for the years 1981–82 to 1985–86 were properly completed and need not be revised under section 263 on the grounds advanced by the Commissioner; the result is in favour of the assessee and against the Revenue.
  • Broader implications: The opinion does not discuss or announce any broader legal doctrine beyond its application to the facts; it emphasizes evidentiary sufficiency (i.e., suspicion is not proof), proper supervisory monitoring of assessments, and that section 263 should not be used where assessments were not shown to be erroneous or prejudicial on the record before the court/tribunal.
  • No new precedent: The opinion does not describe the setting of a novel precedent; it applies established evidentiary and procedural principles to the facts of the case.

Note: This summary is based exclusively on the text of the provided opinion and does not add facts or inferences not contained in that text.

Show full summary ...

    Commissioner Of Income-Tax v. Hastings Properties

    Y.R Meena, J.:— On an application under section 256(2) of the Income-tax Act, 1961, this court has directed the Tribunal to refer the following questions set out in para. 1 at page 2 of the application:

    “1. Whether, on the facts and in the circumstances of the case, the Tribunal was correct in law in annulling the impugned order of the Commissioner of Income-tax dated June 10, 1986, passed under section 263 of the Income-tax Act, 1961?

    2. Whether the findings of the Tribunal leading to the conclusion that the order of the Commissioner of Income-tax dated June 10, 1986, was not valid in law are unreasonable and perverse?”

    2. The assessee is a partnership firm and the firm carries on business of construction equipment, building materials, electrical fittings, acquiring and owning immovable properties, real estates, including rights therein, renting out properties as acquired and also deals in shares and securities. The assessment years involved in this case are 1981–82 to 1985–86. The assessments in all these years are completed under section 143(3) of the Act. On a scrutiny of the assessment records for these years the Commissioner of Income-tax has taken the view that the assessment orders in these years of the Income-tax Officer are erroneous and prejudicial to the interests of the Revenue on the following grounds:

    “(i) The price of the leasehold land was found to be of the order of Rs. 24 lakhs.

    (ii) The acquisition of the leasehold right over 21 cottahs of land for a period of 75 years against the consideration of a mere deposit of Rs. 1 lakh.

    (iii) While the cost of construction of building was computed at Rs. 100 per sft. The seized records indicated a much higher cost of construction as indicated therein, in the sale of premises.

    (iv) The receipts of on-money involved.

    (v) The proceeds on the demolition of the old building not estimated correctly.

    (vi) The crediting of the personal accounts of the partners on revaluation of the leasehold property to the extent of Rs. 74,12,700 without a corresponding reflection in the wealth-tax returns of the respective partners; and

    (vii) Non-verification of the loans alleged to have been received.”

    3. A show-cause notice was issued to the assessee by the Commissioner of Income-tax, why these assessment orders in these years should not be revised under section 263 of the Act. After hearing the assessee, the Commissioner of Income-tax in his order held that—

    (a) The price of land paid by the assessee to the lessor could be taken at Rs. 22,84,168.

    (b) The assessee has received on-money to the tune of Rs. 1,02,45,000 on the sale of flats.

    (c) The Assessing Officer should have included Rs. 51,000 towards the sale proceeds from the sale of materials which was sold by the assessee on demolition of the old building.

    4. Therefore, the Commissioner of Income-tax has directed the Assessing Officer to examine the question regarding cost of construction of the building, receipt of on money, examine to add Rs. 23,000 on account of sale proceeds of the building material and verify the loans which the assessee claimed to have taken from different parties. The case of the assessee before the Tribunal was that there was no material before the Commissioner of Income-tax to estimate the cost of land at Rs. 22,84,168, which was taken on lease. The assessment order was passed and assessment proceedings were monitored by the Commissioner of Income-tax (Investigation), all the relevant materials were collected and on record for making the assessments, the on money theory of the Commissioner is baseless. For sale proceeds of the building material the assessee has explained that though earlier the amount of Rs. 51,000 was offered by A.R Sharma but that could not be accepted as there was stay of the court on demolition work. Therefore, that firm withdrew from the offer and the material ultimately was sold for Rs. 28,000. Therefore, there is no question of taking sale proceeds at Rs. 51,000 against Rs. 28,000.

    5. The Tribunal has framed (vii) questions to consider whether the Commissioner of Income-tax was justified in setting aside the assessment orders and the questions which are as under:

    (i) Whether the assessments are made without proper enquiry by the Income-tax Officer?

    (ii) the price of the leasehold land was found to be of the order of Rs. 24 lakhs and the leasehold right over 21 cottahs of land for a period of 75 years against the consideration of a mere deposit of Rs. 1 lakh whether justified?

    (iii) while the cost of construction of building was computed at Rs. 100 per sq. ft. The seized records indicated a much higher cost of construction as indicated therein, in the sale of premises;

    (iv) the receipts of on money involved;

    (v) the proceeds on the demolition of the old building;

    (vi) the crediting of the personal accounts of the partners on revaluation of the leasehold property to the extent of Rs. 74,12,700 without a corresponding reflection in the wealth-tax returns of the respective partners; and

    (vii) Non-verification of the loans alleged to have been received.

    6. In appeal before the Tribunal, the Tribunal found that the Income-tax Officer had made necessary enquiries and assessment proceedings were monitored by the Commissioner of Income-tax (Vigilance), Calcutta. All directions given by the Commissioner of Income-tax (Appeals) for the necessary enquiries which were complied with, the allegation of the Commissioner of Income-tax regarding the on money on sale of the property as well as the amount of Rs. 22,84,168 stated to have been paid by the assessee for the plot of land is baseless. Loans were genuineness of the cash credits were examined and after due verification those were accepted. Even in the case of the sale proceeds of the demolition material was found justified. Therefore, the Tribunal has quashed the order of the Commissioner of Income-tax under section 263, holding that when the assessment orders were neither erroneous nor prejudicial to the interests of the Revenue, the Commissioner of Income-tax should not set aside those assessment orders.

    7. The Tribunal has also decided the issues on the merits at pages 120-125, which read as under:

    “The assessee succeeds on merits also. The Commissioner of Income-tax in para. 9 of his order concluded that the price of land paid by the assessee to the lessors could be taken at Rs. 22,84,168 based on seized paper marked as ‘BM-I’. Admittedly, it was seized from the office premises of Jaggi Bros. Overseas (P) Ltd. and not from the assessee. It was a typed sheet. The assessee's counsel had given a copy of the same as copied by him (page 64, Paper Book No. II). The original was not shown to us by the Departmental Representative. The said ‘BM-I’ does not contain any name of the person or firm or company to which it relates. It does not contain the name of the property or the building to which it relates. It is not signed by anybody. The area of the land is not mentioned. The additional covered area available was stated to be 22,000 sq. ft. Existing area was stated to be 2,000 sq. ft. Total comes to 24,000 sq. ft. It does not tally with the covered area of 57, 120 sq. ft. in the building known as ‘Hastings Chambers’ undertaken by the assessee. The lessor, Sri P. Mullick, was examined by the Income-tax Officer on March 27, 1985. Nothing was established from it, which goes against the assessee. Further, the Deputy Director of Inspection in his letter dated August 10, 1982 (placed at page 21, of the Department's paper book) addressed to the Commissioner of Income-tax (Investigation) clearly admits that there is no direct evidence as regards payment of substantial on-money on purchase of land from the vendor. Most important factor is that the lease deed was dated February 3, 1979. The assessee closed its books of account on June 30, 1979. Relevant assessment year is 1980–81 and not the assessment years under consideration, viz., 1981–82 to 1985–86. For all the reasons, the Commissioner of Income-tax finding about the price of the land paid by the assessee at Rs. 24,00,000 has no legs to stand. It is not relevant to the assessment years under consideration.

    The next issue relates to alleged receipt of on-money by the assessee against the sale of ownership spaces. For this purpose, the Commissioner of Income-tax relied on ‘page 3 and A-12, page 16 of the seized records and SS-3. ‘The Departmental Representative had supplied us only with a copy of SS-3 at page 18 of his paper books. He has not supplied us with copies of other papers, viz., A-12, pages 3 and 16 (supra). He had supplied copies of annexure A’, ‘annxure B’ and ‘annexure C’ at pages 26 to 28 of his paper book, wherein the figures of Rs. 17,16,244.05, Rs. 7,20,000 and Rs. 8,30,000 were mentioned. Even the Income-tax Officer in his letter dated August 23, 1985, mentioned these figures. Therein he says that a typed statement was recovered at the office of Mr. Jaggi and according to it, the assessee received on-money of Rs. 17,16,244. This statement on which reliance is placed by the Commissioner of Income-tax was not recovered from the assessee. It does not certain any indication as to who received and on whose behalf the amounts of Rs. 2,98,710 in cheques and Rs. 17,35,095 in cash. The Commissioner of Income-tax might have got some suspicion. But suspicion can never take the place of proof. He has not brought any clinching evidence to pin down the issue of alleged receipt of on-money on sale of office space. His reliance on agreement dated August 22, 1980, between the lessor, the assessee, and Bum Standrad Company is also misplaced. It does not point out to receipt of any on-money. It is not even an indicator or pointer to the market price of office space. It was entered into by the assessee under duress as contended by it in its letter dated August 29, 1985, to the Income-tax Officer element of compensation or liquidated damages for vacating the premises occupied previously by Burn Standrad Co. have been included therein. The Commissioner of Income-tax is thoroughly mistaken in observing that in ‘BM-I’ the assessee itself arrived at a profit of Rs. 50 lakhs. It is not known how he came to the said conclusion when the said statement does not contain the name of the assessee, signature of any of the assessee's partners, etc. For the aforementioned reason, the Commissioner of Income-tax finding on the alleged receipt of on-money of Rs. 1,02,45,000 by the assessee on sale of office spaces is without any basis and is based on surmise and suspicion only. It cannot be sustained.

    Regarding the proposed addition of Rs. 23,000 towards materials recovered from the demolished building, the Commissioner of Income-tax does not deny the use of salvaged materials in the building construction. He cannot compute their value merely as the difference between Rs. 51,000 (earlier offer from A.K Sharma and Co.) and Rs. 28,000 (actually credited to profit and loss account). There is no basis for directing the addition of Rs. 23,000.

    There is no finding by the Commissioner of Income-tax that the loans received by the assessee have not been examined by the Income-tax Officer. In fact, all the loans taken by the assessee in all the assessment years under consideration have been fully examined. So, the Commissioner of Income-tax cannot direct the Income-tax Officer to examine the question of verification of loans.

    The cost of construction was also examined by the Income-tax Officer in all the assessment years and he was satisfied. So, the Commissioner of Income-tax is not justified to direct the Income-tax Officer to examine whether the construction cost reflected in the accounts at Rs. 115 per sq. ft. was reasonable or viable. He has not given any reason as to why he is giving such a direction.”

    8. Heard learned counsel for the parties. Considered the submissions and the facts referred to above.

    9. It cannot be said that the Assessing Officer has not made proper investigation for completing the assessments. It is true that all assessments are made on September 27, 1985, the return of income for the assessment year 1981–82 was filed on June 25, and assessment proceedings commenced on August 6, 1982. Several hearings took place in the years 1982–84 and 1985. The relevant order sheets were filed by the Department before the Tribunal. The Income-tax Officer has made enquiries at the instance and under direction of the Commissioner of Income-tax (Investigation), Calcutta. In these cases even the report was called for by the Commissioner of Income-tax (Investigation), Calcutta, and the report was sent through the Inspecting Assistant Commissioner, Special Range-VI, Calcutta, on June 14, 1985. The Commissioner of Income-tax (Investigation) in his letter dated August 16, 1985, raised certain points, which were to be enquired into, and thereafter the case was to be discussed with him. For enquiry the matter was given to the inspector and the inspector has furnished the report and the matter was again discussed verbally with the Commissioner of Income-tax on September 16, 1985 and September 29, 1985 and thereafter the assessments were completed. In view of these facts, it cannot be said that the assessments were made without proper enquiry.

    10. Whether the assessee has paid Rs. 24 lakhs for the leasehold plot of land, which was taken on lease for 75 years. Firstly, the lease of the plot of land taken is in the relevant assessment year 1980–81 and the assessment years before us are from 1981–82 to 1985–86. The lease deed was executed on February 3, 1979, for a period of 75 years and the assessee was required to pay in addition to a deposit of Rs. 1,00,000, monthly rent of Rs. 3,300 which was to be enhanced by Rs. 330 every ten years. There is no material on record to show that the assessee has paid Rs. 24 lakhs for the plot of leasehold land and when the assessment was completed under the supervision of the Commissioner of Income-tax (Vigilance), we do not find any substance in the view taken by the Commissioner of Income-tax that the assessee had paid Rs. 24 lakhs for acquiring the leasehold plot. The next reason given by the Commissioner of Income-tax is that A.K Sharma has offered Rs. 51,000 for purchase of demolition material but the Income-tax Officer has wrongly accepted the sale proceed amount of Rs. 28,000 as stated above and discussed by the Tribunal. The reason given for accepting Rs. 28,000 was that when A.K Sharma offered Rs. 51,000 for demolition material, but there was a stay of the court in that period. Therefore, demolition was not possible and thereafter he withdrew his offer and ultimately the demolition material was sold for Rs. 28,000. On this account also it cannot be said that the order of the Income-tax Officer was erroneous and prejudicial to the interests of the Revenue.

    11. For the cost of construction the assessee has incurred expenditure of Rs. 1,70,806 on the building in the assessment year 1983–84 and in the assessment year 1984–85 the assessee has incurred expenditure of Rs. 5,78,768. That is direct expenditure and indirect expenditure comes to Rs. 2,47,205 and in the assessment year 1985–86 the assessee has incurred expenditure on construction of Rs. 1,58,29,941. The Assessing Officer has examined this cost of construction, which is fully supported by the vouchers when the expenditure was fully supported by the vouchers what more investigation is required specially in this case when the assessment proceedings were monitored by the Commissioner of Income-tax (Vigilance), Calcutta.

    12. For sale price of new constructions the Commissioner of Income-tax has doubted that on-money has been paid to the assessee. He placed his doubt on seized paper marked BM-1, A-12 and HS-3. According to him, on-money received by the assessee from these different parties for sale of 12, 276 sft. amounted to Rs. 17,16,244 and according to the Commissioner of Income-tax the market price of the property was Rs. 350 per sft.

    13. The Tribunal found that the seized paper referred to by him was not recovered from the assessee and on the basis of that paper and figure he computed the figure of Rs. 1,02,45,000 as on-money received by the assessee. This paper BM-1 did not contain any name of the person or firm or company or the price of property or building to which it related and that paper was not signed also by any one. The Tribunal further found that in view of the aforesaid facts the on-money theory of the Commissioner of Income-tax is baseless and has no legs to stand. More so the Tribunal further found that the Income-tax Officer found that the confirmation letters are filed by the purchasers and income-tax file numbers also obtained by the Income-tax Officer to certify the genuine price paid to the assessee. Therefore, on the on-money theory basis the assessment orders cannot be said to be erroneous and prejudicial to the interests of the Revenue. Considering the aforesaid facts, we found no infirmity in the view taken by the Tribunal on these facts also.

    14. So far as the ground for non-verification of loans is considered. The Tribunal found that the Income-tax Officer has verified the loans in the course of the assessment. Confirmation letters of the creditors were on record when the confirmation letters are filed by the creditors and loans are verified. We do not find any reason to say that the assessment orders are erroneous and prejudicial to the interests of the Revenue on this account. In view of the aforesaid facts it cannot be said that the findings of the Tribunal are unreasonable or perverse when the assessment orders were made after due verification and under the supervision of the Commissioner of Income-tax (Vigilance) and all relevant materials has been collected by the Assessing Officer. The assessment orders cannot be said to be erroneous and prejudicial to the interests of the Revenue. Thus we found no infirmity in the order of the Income-tax Officer.

    15. In the result, we answer question No. 1 in the affirmative, that is, in favour of the assessee and against the Revenue. We answer question No. 2 in the negative, that is, also, in favour of the assessee and against the Revenue.

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    Comments

    Commissioner Of Income-Tax v. Hastings Properties
    (Aug 3, 2001)