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  • provision of Section 14A and in particular sub-section (2) thereof, Rule 8D of the Rules
  • Section 14A of the Income-tax Act, 1961 read with Rule 8D(ii) of the Income Tax Rules.3.
  • Section 14A of the Income Tax Act read with Rule 8D(2)(iii) of the Income Tax Rules. (ii)
  • Section 14A of the Income Tax Act read with Rule 8D(2)(iii) of the Income Tax Rules
  • Sub-section (3) of Section 14A clarifies that the provision of sub-section (2)
  • Sub-rule (1) echoes the provision of sub-sections (2) and (3) of Section 14A
  • provisions of sub-rule (2). Sub-rule (2) of Rule 8D
  • sub-rule (2) of Rule 8D of the Rules
  • sub-rule (2) of Rule 8D.
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Cited by
Citation Codes
Equivalent Citations
citation codes
Case Number
Advocates
Judges
Acts
  • provision of Section 14A and in particular sub-section (2) thereof, Rule 8D of the Rules
  • Section 14A of the Income-tax Act, 1961 read with Rule 8D(ii) of the Income Tax Rules.3.
  • Section 14A of the Income Tax Act read with Rule 8D(2)(iii) of the Income Tax Rules. (ii)
  • Section 14A of the Income Tax Act read with Rule 8D(2)(iii) of the Income Tax Rules
  • Sub-section (3) of Section 14A clarifies that the provision of sub-section (2)
  • Sub-rule (1) echoes the provision of sub-sections (2) and (3) of Section 14A
  • provisions of sub-rule (2). Sub-rule (2) of Rule 8D
  • sub-rule (2) of Rule 8D of the Rules
  • sub-rule (2) of Rule 8D.
Smart Summary

Judgment Summary: Akil Kureshi, J. — Appeal against ITAT order dated 25.11.2016 (Section 14A / Rule 8D)

Factual and Procedural Background

This appeal was filed by the assessee challenging the Income Tax Appellate Tribunal's judgment dated 25.11.2016 concerning the disallowance of Rs. 9,63,355/-. For assessment year 2009-10 the assessee's return showed dividend income of Rs.41.20 lakhs and long-term capital gain of Rs.1.28 crores (both shown as exempt). The assessee held investments of approximately Rs.23.62 crores as on 31.03.2009 and reported nil expenditure in relation to earning the exempt income.

The Assessing Officer issued a show-cause notice after being unconvinced by the assessee's claim of no expenditure; the assessee replied (letter dated 17.10.2011) asserting investments were from own funds and no borrowed funds were used. The Assessing Officer rejected the explanation, observed that certain administrative and other indirect expenses must have been incurred (itemising examples such as documentation, salaries, DEMAT charges and overheads) and computed disallowance under Section 14A read with Rule 8D of the Income-tax Rules. The Commissioner (Appeals) confirmed the Assessing Officer's view. The Tribunal partly allowed the appeal in limited respects but upheld the disallowance under Rule 8D(2)(iii) while not sustaining proportionate interest disallowance under Rule 8D(2)(ii). The present appeal challenged the ITAT decision.

Legal Issues Presented

  1. Whether the Income Tax Appellate Tribunal was right in confirming the disallowance of Rs.9,63,355/- made by the respondent without recording mandatory satisfaction as contemplated under Section 14A of the Income Tax Act read with Rule 8D(2)(iii) of the Income Tax Rules.
  2. Whether the Income Tax Appellate Tribunal was right in confirming the disallowance of Rs.9,63,355/- made under Section 14A read with Rule 8D(2)(iii) without there being any finding by the respondent that the appellant assessee actually incurred such expenditure for earning exempt income.
  3. Whether the order passed by the ITAT is perverse inasmuch as the same has been passed in a mechanical manner without appreciating the documentary evidences placed on record.

Arguments of the Parties

Appellant's Arguments (summarised)

  • The Assessing Officer erred in applying the formula in sub-rule (2) of Rule 8D without recording the mandatory satisfaction rejecting the assessee's accounts which purportedly showed that no expenditure was incurred for earning the exempt income.
  • Mere general observations that some expenditure must have been incurred are insufficient; there must be specific reference to expenditure actually incurred for Section 14A or Rule 8D to apply.
  • Reliance was placed on judicial authorities (Godrej & Boyce Mfg Co. Ltd. v. Dy. CIT and Maxopp Investment Ltd. v. Commissioner of Income-Tax, New Delhi) for the propositions that the issue turns on whether expenditure was actually incurred in relation to exempt income and that if no expenditure is shown to have been incurred, no disallowance can be made.

Revenue / Assessing Officer's Position (summarised from the order)

  • The Assessing Officer was not satisfied with the assessee's claim of nil expenditure. He reasoned that holding and managing substantial investments necessarily entails direct and indirect expenses (examples given: interest, administrative/management charges, documentation, salaries, DEMAT charges, stationery, telephone, computers, office equipment, vehicles).
  • The Assessing Officer noted the assessee did not demonstrate availability of sufficient interest-free funds on the date of investment; on that basis he applied the Rule 8D formula and computed a disallowance (the administrative/overhead component noted was Rs.9.75 lakhs in the AO's reasoning).
  • The Commissioner (Appeals) confirmed the Assessing Officer's findings, and the Tribunal reviewed and largely upheld the view that some expenditure must have been incurred and that Rule 8D(2)(iii) applied where allocation by scientific accuracy was not possible.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Godrej & Boyce Mfg Co. Ltd. v. Dy. CIT [2017] 394 ITR 449 / 247 Taxman 361 / 81 taxmann.com 111 Authority relied on by appellant to show that, where earlier findings established that expenditure was not incurred for earning dividend income, the Assessing Officer could not take a different view; principle concerning actual incurrence of expenditure relevant under Section 14A. The Court acknowledged the observations in this judgment but concluded that the Assessing Officer had recorded sufficient reasons in the assessment order to be satisfied that the assessee's claim of no expenditure was incorrect; therefore Rule 8D application was held permissible in the present facts.
Maxopp Investment Ltd. v. Commissioner of Income-Tax, New Delhi [2012] 347 ITR 272 / [2011] 203 Taxman 364 / 15 taxmann.com 390 Cited for the proposition that Section 14A contemplates actual expenditure incurred in relation to exempt income, and if no expenditure is incurred then no disallowance can be made. The Court accepted the proposition as sound law but found that, on the facts, the Assessing Officer had material and reasons to reject the assessee's claim of nil expenditure and therefore the Rule 8D computation was properly applied.

Court's Reasoning and Analysis

The Court proceeded by outlining the statutory framework and then testing the Assessing Officer's actions against that framework.

  1. Statutory scheme:
    • Section 14A(1) provides for disallowance of expenditure incurred in relation to income which does not form part of the total income.
    • Section 14A(2) permits the Assessing Officer to determine the amount of such expenditure where he is not satisfied with the correctness of the assessee's claim having regard to the accounts.
    • Section 14A(3) applies where the assessee claims that no expenditure has been incurred; it clarifies that subsection (2) applies in such cases and shifts the burden to the assessee to establish absence of disallowable expenditure.
  2. Rule 8D of the Income-tax Rules gives a method for determining the amount of expenditure attributable to exempt income, with sub-rule (2) (prior to its amendment effective 02.06.2016) providing a formula to apportion expenditure where allocation is not possible with scientific accuracy. Sub-rule (1) echoes subsections (2) and (3) of Section 14A.
  3. The statutory prerequisites require the Assessing Officer to arrive at a satisfaction that the assessee's claim regarding expenditure is incorrect before applying the Rule 8D formula. The Court emphasised that the statute does not prescribe a particular mode or form for arriving at that satisfaction.
  4. Application to the facts:
    • The Assessing Officer articulated detailed reasons for rejecting the assessee's assertion of nil expenditure (noting the nature and scale of investments, examples of administrative expenses, and the absence of evidence of interest-free funds available on the date of investment).
    • The Tribunal reviewed the material and observed the assessee held substantial investments (noted figures as to investments on 31/03/2009 and 31/03/2008) and that even a director devoted time to investment administration; therefore the contention of NIL administrative expenditure was not credible on the facts.
    • The Tribunal also observed that where allocation cannot be done with scientific accuracy, Rule 8D(2)(iii) is applicable. The Court found that the Assessing Officer's decision to apply the Rule 8D formula was supported by sufficient material and suitably recorded in the order of assessment.
    • Separately, both the Tribunal and the Court accepted that the disallowance of proportionate interest under Rule 8D(2)(ii) was not sustainable because the assessee's own capital together with accumulated reserves exceeded the corresponding investments (this particular aspect remained unrebutted).
  5. Conclusion of reasoning: because the Assessing Officer had given detailed reasons and recorded the basis for rejecting the assessee's nil-expenditure claim, and the Tribunal had confirmed that view, the Court held the application of the Rule 8D formula was correct and lawful.

Holding and Implications

Holding: The tax appeal is DISMISSED.

Direct consequences and implications:

  • The Assessing Officer's application of the Rule 8D formula (sub-rule (2)) and the resulting disallowance (as sustained by the Tribunal) were upheld by the Court because the AO had recorded sufficient reasons to be satisfied that the assessee's claim of no expenditure was incorrect.
  • The Court agreed with the Tribunal's approach that where an assessee claims nil expenditure, Section 14A(3) shifts the burden to the assessee to prove absence of disallowable expenditure, and where allocation cannot be done with scientific accuracy Rule 8D(2)(iii) is a permissible method of computation.
  • The Court accepted the Tribunal's finding that the disallowance towards proportionate interest under Rule 8D(2)(ii) was not sustainable on the facts (own capital and reserves exceeded corresponding investment) — that aspect was not upheld against the assessee.

No new legal principle or precedent was created by this decision; the Court applied existing statutory provisions (Section 14A and Rule 8D) and affirmed that an Assessing Officer's recorded satisfaction, supported by material, suffices to invoke Rule 8D even where the assessee claims nil expenditure.

    Devarsons Industries (P.) Ltd. v. Assistant Commissioner of Income Tax (OSD)

    ORDER

    Akil Kureshi, J. - This appeal is filed by the assessee to challenge the judgment of the Income Tax Appellate Tribunal dated 25.11.2016. Following questions have been presented for our consideration.

  • "(i) Whether in the facts and circumstances of the case, the Income Tax Appellate Tribunal was right in confirming the disallowance of Rs.9,63,355/- made by the respondent without recording mandatory satisfaction as contemplated under Section 14A of the Income Tax Act read with Rule 8D(2)(iii) of the Income Tax Rules.
  • (ii) Whether in the facts and circumstances of the case, the Income Tax Appellate Tribunal was right in confirming the disallowance of Rs.9,63,355/- made under Section 14A of the Income Tax Act read with Rule 8D(2)(iii) of the Income Tax Rules without there being any finding by the respondent that the appellant assessee has actually incurred such expenditure for earning exempt income.
  • (iii) Whether in the facts and circumstances of the case, the order passed by the ITAT is perverse inasmuch as the same has been passed in mechanical manner without appreciating the documentary evidences placed on record."
  • 2. Though three questions are framed, the issue is common namely of disallowance of a sum of Rs. 9,63,355/- made by the Assessing Officer and confirmed up to the level of the Income Tax Appellate Tribunal in terms of Section 14A of the Income-tax Act, 1961 read with Rule 8D(ii) of the Income Tax Rules.

    3. For the assessment year 2009-10, the assessee had filed the return of income in which the assessee had shown dividend income of Rs.41.20 lakhs (rounded off) and long-term capital gain of Rs.1.28 crores (rounded off) as income exempt from tax. To earn such income, the assessee had made investment of Rs.23.62 crores (rounded off) as on 31.03.2009. The assessee had showed Nil expenditure for earning such tax exempt income. The Assessing Officer was not convinced about this claim of the assessee and therefore issued a show-cause notice to the assessee why disallowance under Section 14A of the Act read with Rule 8D of the Rules should not be made. The assessee replied to the show-cause notice under letter dated 17.10.2011 contending inter alia that the assessee had invested its own funds. No borrowed funds were utilized. The question of investment out of borrowed funds, therefore, does not arise.

    4. The Assessing Officer did not accept the explanation of the assessee. The main contention of the assessee was with respect to the interest expenditure. He noted that the assessee had not referred to any indirect expenditure. He was of the opinion that in such investment activity there would be certain expenditure involved. Out of the total expenditure of the assessee for its business, a portion would be included towards expenditure for such investment activity and for earning tax exempt income such as cost of interest, administrative and management associated charges etc. He was also of the opinion that the assessee would have incurred administrative expenditure such as documentation, salaries of employees, handling the investment portfolio, administrative overheads like stationery, telephone, computer, office equipments, vehicles etc which came to Rs. 9.75 lakhs which he disallowed. He was, therefore, of the opinion that the assessee had incurred direct or indirect expenditure for earning such income which was claimed to be exempt from payment of tax. He also noted that the assessee merely contended that no borrowed funds were diverted but failed to establish that the assessee had sufficient interest free funds on the date of investment. On these grounds, the Assessing Officer rejected the assessee's explanation and proceeded to compute the expenditure to be disallowed in terms of Rule 8D of the Rules.

    5. The matter was carried in appeal. The Commissioner (Appeals) confirmed the view of the Assessing Officer upon which the assessee approached the Tribunal. The Tribunal by the impugned judgment rejected the appeal making following observations:

    "8. We have carefully considered the rival submissions and gone through the orders of the authorities below. The solitary issue for adjudication is correctness of the disallowance under section 14A of the Act. We note that the assessee holds substantial investments which is pegged at Rs.41.92 crores as on 31/03/2009 and Rs.35.16 crores as on 31/03/2008. We simultaneously note from the 'statement of facts' filed before the CIT (A) that assessee in its own admission has admitted that one of the Directors used to devote one hour per week for the administration of the investment. Nonetheless, the assessee has not recorded any amount attributable to the earning of tax-free income by way of dividend.

    9. We do not find any rationale in the argument put forth on behalf of the assessee that no expenditure has been incurred in relation to income which does not form part of the total income. It is an common knowledge that holding of such investments would entail ordinary expenses like DEMAT charges and engagement of senior management. We also notice that there are several instances of change in the investment during the year qua the investments held in the previous year. Naturally, the Board and Senior Management has devoted time and attention in the decision-making process. Therefore, the contention of the assessee about NIL administrative expenditure for holding the investment stands belied in the facts of the case. In the event, the Assessee claims that no expenditure has been incurred by him in relation to exempt income, the case gets covered by section 14A(3) of the Act. Section 14A(3) of the Act specifically excludes applicability of section 14A(2) and shifts the burden entirely on Assessee to establish absence, if any, of expenditure disallowable under section 14A of the Act. Besides, Rule 8D(2)(iii) of the IT Rules, 1962 has been enacted for such eventualities where it is not possible to allocate the indirect expenditure towards administration, etc. with any scientific accuracy. In the circumstances, we do not see any logic in the arguments of the assessee insofar as disallowance under Rule 8D(2) (iii) is concerned. However, insofar as disallowance of interest towards interest is concerned, we find that the averment made on behalf of the assessee that the own capital together with accumulated reserves are in excess of corresponding investment remains unrebutted. Therefore, in view of the long line of the judicial precedent on the issue, the disallowance towards proportionate interest under Rule 8D(2)(ii) is not sustainable in the facts. As a result, order of the CIT (A) is partially allowed in terms of our observations noted above."

    6. Learned counsel Shri Hemani for the appellant contended that the Assessing Officer committed serious error in applying the formula contained in sub-rule (2) of Rule 8D of the Rules without recording his satisfaction rejecting the assessee's accounts reflecting that no expenditure was incurred for earning such tax exempt income. He submitted that mere general observations that some expenditure must have been incurred would not be sufficient and unless the Assessing Officer makes specific reference to the expenditure actually incurred, neither Section 14A nor Rule 8D would apply. In this context, counsel relied on the judgment of the Supreme Court in case of Godrej & Boyce Mfg Co. Ltd. v. Dy. CIT [2017] 394 ITR 449/247 Taxman 361/81 taxmann.com 111 in which finding that in the earlier years the issue of the expenditure sought to be disallowed had actually been incurred in earning dividend income was already decided in favour of the assessee and therefore in the present order the Assessing Officer could not have taken a different view. Reliance was also placed on a decision of the Division Bench of Delhi High Court in case of Maxopp Investment Ltd…. v. Commissioner Of Income-Tax, New Delhi [2012] 347 ITR 272/[2011] 203 Taxman 364/15 taxmann.com 390 in which it was observed that what is in contemplation of Section 14A of the Act is the actual expenditure incurred in relation to or in connection with the earning. Exempt income has a corollary. If no expenditure is incurred, no disallowance can be made.

    7. With the observations made by the courts in the above noted judgments, there can be little quarrel. What Section 14A of the Act envisages is disallowance of expenditure incurred by an assessee in relation to income which does not form part of the total income. This flows from sub-section (1) of Section 14A. Sub-section (2) of Section 14A permits the Assessing Officer to determine such amount of expenditure if he having regard to the accounts of the assessee is not satisfied with the correctness of the claim of the assessee in respect of such expenditure. Sub-section (3) of Section 14A clarifies that the provision of sub-section (2) would apply also in relation to a case where when the assessee claims that no expenditure has been incurred in relation to the income which does not form part of the total income.

    8. To give effect to the provision of Section 14A and in particular sub-section (2) thereof, Rule 8D of the Rules provides the method for determining the amount of expenditure in relation to the income not includable in the total income. Sub-rule (1) echoes the provision of sub-sections (2) and (3) of Section 14A where it provides that if the Assessing Officer having regard to the accounts of the assessee is not satisfied with the correctness of the claim of the expenditure or the claim made is that no expenditure has been incurred in relation to the income which does not form part of the total income, he would determine the amount of expenditure in relation to such income in accordance with the provisions of sub-rule (2). Sub-rule (2) of Rule 8D prior to its amendment with effect from 02.06.2016 provided a formula to apportion the expenditure in connection with the tax free income. Section 14A as well as Rule 8D require the Assessing Officer to arrive at a satisfaction that the claim of the expenditure made by the assessee is not correct. It is only then he can apply the formula under sub-rule (2) of Rule 8D. However, these statutory provisions do not require that such satisfaction must be arrived at in a particular manner. As long as there is sufficient material to enable the Assessing Officer to arrive at such a satisfaction and which is also recorded by him in the order of assessment, the requirements of the statute would be satisfied. In the present case, we have noted that the Assessing Officer has given detailed reasons for discarding the assessee's theory that to earn the assessable income the assessee incurred no expenditure whatsoever. The Tribunal confirmed such view. Decision of the Assessing Officer to apply the formula under Rule 8D was therefore correct. Tax appeal is accordingly dismissed.

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    Devarsons Industries (P.) Ltd. v. Assistant Commissioner of Income Tax (OSD)
    (Jul 25, 2017)