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Smart Summary

Factual and Procedural Background

This appeal arises from order dated 07.11.2017 of the Commissioner of Income Tax (Appeals)-19, New Delhi, in respect of assessment year 2010-11. The assessee, M/s. Vimoni India Pvt. Ltd., a resident company manufacturing PET and HDPE bottles, jars, caps and closures, filed a return on 15.10.2010 declaring nil income. During assessment proceedings the Assessing Officer (AO) noticed a claim of deduction of Rs. 86,63,158 under section 80IC of the Income-tax Act, 1961 and called for supporting evidence.

The assessee submitted documents showing a manufacturing unit at Barotiwala, Himachal Pradesh, and asserted compliance with section 80IC conditions. The AO disallowed the 80IC deduction on the ground that the products manufactured fall within the 13th Schedule to the Act and hence do not satisfy section 80IC(2)(a). The assessee appealed to the Commissioner (Appeals), who — relying on the Delhi High Court decision in Ajay Kumar Sharma vs. CIT (351 ITR 428) — held the AO's categorisation as unsustainable but nonetheless upheld the disallowance because the assessee allegedly failed to furnish required details and because earlier years were processed under section 143(1). The Revenue did not appeal the Commissioner (Appeals)'s view on the Schedule 13 issue to a higher forum.

The assessee challenged (inter alia) the disallowance of the section 80IC claim, the disallowance of Rs. 55,00,000 representing fixed assets written off, and an addition of Rs. 1,85,559 under section 43B for non-payment of PF/ESI. The Income Tax Appellate Tribunal (Delhi Bench 'F') heard the matter on 10.05.2022 and reserved pronouncement, delivering the order on 14.07.2022.

Legal Issues Presented

  1. Whether the assessee is entitled to deduction under section 80IC of the Income-tax Act for the assessment year 2010-11 in respect of manufacturing PET and HDPE bottles, jars, caps and closures.
  2. Whether the disallowance of Rs. 55,00,000 (fixed assets written off) and the addition of Rs. 1,85,559 under section 43B (non-payment of PF/ESI) are to be accepted, and if not, whether the assessee can claim section 80IC deduction on account of the increased profits resulting from those disallowances.
  3. Whether conditions for claiming deduction under section 80IC, having been examined and allowed in earlier assessment years, can be re-opened in a subsequent year without any new material.

Arguments of the Parties

Appellant's Arguments

  • The assessee commenced manufacturing in financial year 2004-05 (Form No. 10CCB shows commencement on 17.06.2004) and first claimed section 80IC in assessment year 2005-06; the claim was examined and allowed in the first year and in subsequent years (notably assessment year 2007-08 where assessment under section 143(3) resulted in allowance).
  • The assessee undertook substantial expansion in financial year 2006-07 with investment of approximately Rs. 3,99,49,251 in plant & machinery, and furnished relevant documents (approvals, registration under Central Excise, returns under Central Excise) to substantiate compliance with section 80IC conditions.
  • Once the fulfillment of section 80IC conditions is examined and accepted in the first year of claim, the same cannot be re-examined in a later year absent new facts or material; therefore the section 80IC deduction should be allowed for 2010-11.
  • Regarding the disallowances (fixed assets written off and PF/ESI), since these increase the assessee's profits, the assessee is entitled to claim section 80IC deduction on the enhanced profits; reliance placed on CBDT Circular No. 37 of 2016 and several decisions supporting allowance of deduction on enhanced profits resulting from additions.
  • Relied on several judicial decisions (listed in the record) including Ajay Kumar Sharma vs. CIT and others to support the above positions.

Respondent's (Departmental) Arguments

  • The Departmental Representative strongly relied upon the findings of the Assessing Officer and the Commissioner (Appeals), including the view that the assessee failed to furnish required details to substantiate fulfillment of section 80IC conditions, and the suggestion that earlier years were not fully examined because returns were processed under section 143(1).
  • The Revenue maintained the disallowances made by the AO and the observations recorded in the appellate order.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Ajay Kumar Sharma vs. CIT, 351 ITR 428 (Delhi High Court) Held (as cited in the order) that deduction under section 80IC is allowable on PET and HDPE bottles. The Commissioner (Appeals) relied on this decision to hold that the AO's conclusion that the products fall in Schedule 13 was unsustainable; the Tribunal noted this decision and that Revenue did not appeal that aspect.
CIT vs. International Tractor Ltd., 2017 397 ITR 696 (Delhi High Court) Cited by the assessee (as part of authorities) in support of the proposition that prior examination and allowance of section 80IC conditions precludes re-examination in subsequent years without new material. The Tribunal recorded that decisions cited by the assessee, including this one, support the view that the AO cannot reject a previously examined and allowed 80IC claim in a later year without new facts; the Tribunal relied on that line of authority in allowing the appeal.
CIT vs. Tata Communications Internet Services Ltd., [2012] 251 CTR 290 (Delhi High Court) Cited by the assessee in support of the overall proposition on examination/estoppel in subsequent years (as filed by counsel). Used by the Tribunal as one of the authorities that, collectively, underpin the Tribunal's conclusion that the disallowance was unsustainable.
CIT vs. Delhi Press Patra Prakashan Ltd., [2013] 355 ITR 14 (Delhi High Court) Cited by the assessee as supporting authority relevant to the contested principle (earlier examination precluding later re-examination). Taken into account by the Tribunal as part of the body of decisions relied upon by the assessee to support its case; contributed to Tribunal's conclusion to allow the deduction.
M/s. Hughes Communications India Ltd. Vs. DCIT (ITA No.2346/Del/2014 & others, dated 14.09.2021) Cited by the assessee among authorities supporting the entitlement to section 80IC deduction / related procedural principle. Part of the authorities which the Tribunal noted as supporting the assessee's contention; the Tribunal found the collective weight of authorities persuasive.
Shree Veer Aromatics Herbs Products vs. ITO, [2014] 147 ITD 86 (Delhi ITAT) Cited by the assessee as supporting authority for the claimed proposition regarding section 80IC and related procedural issues. Included among judicial precedents the Tribunal considered as supporting the assessee's stance that earlier allowance should preclude later denial without new material.
ACIT vs. M/s. LVP Foods Pvt. Ltd. (ITA No. 937/Del/2017) Cited by the assessee as part of the supporting decisions on the point. Noted by the Tribunal as one of the precedents relied upon by counsel; assisted the Tribunal in forming its view.
M/s. Ace Multi Axes Systems Ltd. vs. DCIT (ITA No. 477 of 2013) Cited by the assessee as authority in support of the general proposition advanced. Considered among the cases relied upon which supported the Tribunal's conclusion to allow the section 80IC claim.
DCIT vs. Selvel Advertising (P.) Ltd., [2015] 58 taxmann.com 196 (Kolkata - Trib.) Cited by the assessee in the corpus of authorities relied upon. Referenced by the Tribunal as part of the supporting case law invoked by the assessee; contributed to the Tribunal's conclusion.
CIT vs. Gem Plus Jewellery India Ltd., [2010] 233 CTR 248 (Bombay High Court) Cited by the assessee in support of the contention that deduction under section 80IC can be claimed on enhanced profits resulting from additions/disallowances. The Tribunal accepted the general principle (as supported by these decisions) and directed the AO to allow section 80IC deduction on the disputed additions.
Sanghvi Jewellery Mfg. Co. (P.) Ltd. vs. ITO, [2012] 145 TTJ 137 (Mumbai ITAT) Cited to support the proposition that where additions increase profits, deduction under section 80IC may be available on the enhanced profit (as used by the assessee). Used by the Tribunal to support its direction that the assessee is entitled to claim section 80IC on the enhanced profit resulting from the disallowances.
ITO vs. Anthelio Business Technologies (P.) Ltd., [2017] 78 taxmann.com 203 (Mumbai - Trib.) Cited by the assessee in support of entitlement to section 80IC deduction on enhanced profits owing to additions. Referenced by the Tribunal among decisions that justify allowance of section 80IC on the increased profit; helped the Tribunal order relief.
Patni Telecom Solutions (P.) Ltd. vs. ITO, [2013] 58 SOT 146 (Hyd. ITAT) Cited by the assessee as authority relevant to the proposition that section 80IC deduction may be claimed on increased profits resulting from additions. Included among the authorities relied upon by the assessee and considered by the Tribunal in directing allowance of section 80IC on the additions.

Court's Reasoning and Analysis

The Tribunal's reasoning proceeded in several discrete steps, based strictly on the materials and submissions on record:

  1. The Tribunal accepted as undisputed that the assessee had established a manufacturing unit at Barotiwala, Himachal Pradesh, with commencement of manufacturing activity shown as 17.06.2004 (Form No.10CCB) and that the first year of claiming section 80IC was assessment year 2005-06. The assessee also demonstrated substantial expansion in financial year 2007-08 with investment of about Rs. 4 crores in plant and machinery.
  2. The AO's sole recorded reason for rejecting the 80IC deduction was that the products manufactured by the assessee fall within Schedule 13 of the Act and therefore do not satisfy section 80IC(2)(a). The Commissioner (Appeals) held this finding to be unsustainable in view of the Delhi High Court decision in Ajay Kumar Sharma. The Revenue did not appeal that particular finding.
  3. The Commissioner (Appeals) nonetheless sustained the disallowance on two other, non-specific bases: (a) a general observation that the assessee failed to furnish required details (without specifying the details), and (b) an assertion that in earlier years the fulfillment of 80IC conditions was not examined because returns were processed under section 143(1).
  4. The Tribunal examined the record and found those additional bases unsupported by the materials: the record showed the 80IC claim was examined in the first year of claim (2005-06) and again in assessment year 2007-08 where the assessment was completed under section 143(3) and the AO specifically examined and allowed the 80IC deduction.
  5. The Tribunal articulated the legal proposition (supported by the line of authorities cited by the assessee) that where the conditions for claiming a deduction under section 80IC have been examined and satisfied in an earlier assessment year, a later assessment year cannot deny the same deduction unless new facts or material are brought on record. The Tribunal found no new facts or materials in the assessment year under appeal to justify reopening the matter.
  6. Applying these principles, the Tribunal concluded that the disallowance of the 80IC claim for assessment year 2010-11 was unsustainable and therefore directed the Assessing Officer to allow the deduction.
  7. On grounds 2 and 3 (disallowance of Rs. 55,00,000 fixed assets written off and addition of Rs. 1,85,559 under section 43B), the Tribunal accepted appellant's narrower contention at hearing: since these disallowances increase the assessee's profits, the assessee is entitled to claim section 80IC deduction on the enhanced profits. The Tribunal noted the CBDT Circular No. 37 of 2016 and authorities cited by the assessee and, in principle, agreed that the assessee should be granted the section 80IC deduction in respect of such enhanced profit. The Tribunal therefore directed the AO to allow the section 80IC claim on those additions.

Holding and Implications

Core Holding: APPEAL ALLOWED

The Tribunal allowed the appeal in respect of the disallowance of the section 80IC deduction for assessment year 2010-11 and directed the Assessing Officer to allow the assessee's claim of deduction under section 80IC of the Income-tax Act. Further, the Tribunal directed that the section 80IC deduction be allowed in relation to the disputed additions (the fixed assets written off of Rs. 55,00,000 and the addition of Rs. 1,85,559 under section 43B), thereby permitting the assessee to claim the deduction on the enhanced profit resulting from those disallowances.

Direct consequences:

  • The Assessing Officer is to allow the assessee's section 80IC deduction for assessment year 2010-11 as directed by the Tribunal.
  • The Assessing Officer is to allow the section 80IC deduction in respect of the additions/disallowances of Rs. 55,00,000 and Rs. 1,85,559 (i.e., on the enhanced profits resulting from those items).

Broader implications:

The order rests on existing judicial authorities and factual findings particular to the assessee's earlier examinations and allowances of section 80IC; the Tribunal did not purport to lay down a new rule of law beyond applying the cited precedents and established principle that an earlier, thorough examination and allowance of entitlement precludes later denial absent new facts or material. The decision's application is confined to the parties and facts before the Tribunal; no novel legal precedent is announced in this order.

Order pronounced in open court on 14th July, 2022. Members: Pradip Kumar Kedia (Accountant Member) and Saktijit Dey (Judicial Member).

Show full summary ...

    M/s. Vimoni India Pvt. Ltd., New Delhi v. DCIT, New Delhi

    IN THE INCOME TAX APPELLATE TRIBUNAL,

    DELHI BENCH: 'F' NEW DELHI

    BEFORE SHRI SAKTIJIT DEY, JUDICIAL MEMBER

    AND

    SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER

    ITA No.1510/Del/2015 Assessment Year: 2010-11 M/s. Vimoni India Pvt. Ltd., Vs. Deputy Commissioner of 3-D, Vandana Building, Income-tax,

    11 Tolstoy Marg, Circle-17(1), New Delhi New Delhi

    PAN :AAACV3859K

    (Appellant) (Respondent)

    Appellant by Sh. Ajay Wadhwa, CA Ms. Bharti Sharma, CA

    Respondent by Sh. Vijay Kataria, Sr. DR Date of hearing 10.05.2022

    Date of pronouncement 14.07.2022

    ORDER

    PER SAKTIJIT DEY, JM:

    This is an appeal by the assessee against order dated 07.11.2017 of learned Commissioner of Income Tax (Appeals)-19, New Delhi, pertaining to assessment year 2010-11.

    2. Grounds raised by the assessee are as under:

    1. The order dated 30.10.2014 passed by the learned Commissioner of Income-tax (Appeal) is bad in law and in facts.

    2. That the Ld. CIT(A) has erred in upholding the disallowance of Rs 55,00,000/- of fixed assets written off in profit and loss account.

    1

    2

    3. That the Ld. CIT(A) has erred in upholding the addition of Rs 1,85,559/- u/s 43B on account of nonpayment contribution to PF/ESI.

    4. That the Ld. CIT(A) has erred in upholding disallowance of claim made u/s 80IC without considering the fact that the similar claim has been accepted in earlier years.

    5. The appellant craves leave to alter, amend or add any other ground of appeal either

    3. Grounds no. 1 to 5, being general grounds, do not require specific adjudication.

    4. Since ground no. 4 will have a bearing on ground nos. 2 and 3, at the outset, we proceed to decide ground no. 4. The issue raised in ground no. 4 relates to disallowance of assessee's claim of deduction under section 80IC of the Income-tax Act, 1961 (in short 'the Act').

    5. Briefly the facts are, the assessee, a resident company, is engaged in the business of manufacturing of plastic packaging products such as PET and HDPE bottles, jars, caps and closures. For the assessment year under dispute, the assessee filed its return of income on 15.10.2010 declaring nil income. In course of assessment proceeding, the Assessing Officer, while verifying the return of income filed by the assessee, noticed that the assessee had claimed deduction of Rs.86,63,158/- under section 80IC of the Act. Noticing this, the Assessing Officer called upon the assessee to furnish supporting evidence to justify the deduction claimed. In

    3

    response, the assessee filed a detailed submission along with supporting evidences stating that it has set up a manufacturing unit at Barotiwala, Himachal Pradesh, which has fulfilled all the conditions of section 80IC of the Act. After perusing the documents filed and considering the submissions made, the Assessing Officer was of the view that the products manufactured by the assessee are in the nature of goods and articles specified in the 13th Schedule of the Act. Thus, he held that the assessee is not eligible to claim deduction under section 80IC of the Act, in view of the conditions imposed under section 80IC(2)(a) of the Act. Accordingly, he disallowed assessee's claim of deduction. Contesting the disallowance of deduction claimed under section 80IC of the Act, assessee preferred an appeal before learned Commissioner (Appeals).

    6. Being satisfied with the submissions of the assessee that as per the decision of the Hon'ble Delhi High Court in case of Ajay Kumar Sharma Vs. CIT, 351 ITR 428, deduction under section 80IC is allowable on PET and HDPE bottles, learned Commissioner (Appeals) held that the Assessing Officer's view that section 80IC deduction is not allowable on the products manufactured by the assesse is unsustainable. However, he upheld the disallowance of

    4

    deduction claimed under Section 80IC of the Act on the reasoning that the assessee failed to furnish the required details to substantiate that the conditions of section 80IC of the Act were fulfilled.

    7. Before us, Sh. Ajay Wadhwa, learned Counsel appearing for the assessee, submitted, the assessee had commenced its manufacturing process in the financial year relevant to the assessment year 2005-06 and deduction was claimed for the first time in assessment year 2005-06. He submitted, assessee's claim of deduction under section 80IC of the Act has been allowed from assessment year 2005-06 till 2009-10. He submitted, in the financial year 2006-07, the assessee had undertaken substantial expansion of the unit by investing an amount of Rs. 3,99,49,251/-

    . He submitted, all relevant and necessary documents relating to setting up of unit, the investment made in substantial expansion of the unit, approval of the competent authority, registration under the Central Excise Act as well as returns filed under the Central Excise Act were also furnished before the departmental authorities. Drawing our attention to section 80IC of the Act, learned Counsel submitted that all the conditions of the said provision, including the conditions relating to substantial expansion have been fulfilled

    5

    by the assessee. He submitted, fulfillment of conditions for claiming deduction under section 80IC of the Act has to be examined in the first year of claim of deduction. He submitted, once, the issue is examined in the first year of claim and the Assessing Officer, having factually examined the issue, if comes to a conclusion that all the conditions of section 80IC of the Act are satisfied, the matter ends there and fulfillment of conditions under section 80IC cannot be examined in any future assessment year. He submitted, assessee's claim of deduction under section 80IC of the Act was not only examined in assessment year 2005-06, the first year of claim, but, was also examined in subsequent assessment years. Rebutting the observations of the departmental authorities that in subsequent years, the assessments have been made under section 143(1) and not under section 143(3), learned counsel drew our attention to the assessment order passed under section 143(3) of the Act for the assessment year 2007-08, wherein the Assessing Officer, after examining assessee's claim of deduction under section 80IC of the Act, has allowed. Thus, he submitted, deduction claimed under section 80IC off the Act should be allowed. In support of such contention, learned counsel relied upon the following decisions:

    6

    1. CIT Vs. International Tractor Ltd. {2017} 397 ITR 696 (Delhi High Court)

    2. CIT Vs. Tata Communications Interned Services Ltd. [2012] 251 CTR 290 (Delhi High Court)

    3. CIT Vs. Delhi Press Patra Prakashan Ltd. [2013] 355 ITR 14 (Delhi High Court)

    4. M/s. Hughes Communications India Ltd. Vs. DCIT (ITA No.2346/Del/2014 along with other appeals, dated 14.09.2021)

    5. Shree Veer Aromatics Herbs Products Vs. ITO [2014] 147 ITD 86 (Delhi ITAT)]

    6. ACIT Vs. M/s. LVP Foods Pvt. Ltd. (ITA No. 937/Del/2017).

    7. M/s. Ace Multi Axes Systems Ltd. Vs. DCIT (ITA No. 477 of 2013)

    8. DCIT Vs. Selvel Advertising (P.) Ltd. [2015] 58 taxmann.com 196 (Kolkata -Trib.)

    8. Learned Departmental Representative strongly relied upon the observations of learned Commissioner (Appeals).

    9. We have considered rival submissions in the light of decisions relied upon and perused the materials on record. Undisputedly, the assessee has set up a manufacturing unit for manufacture of PET, HDPE bottles etc. at Barotiwala, Himachal Pradesh. As per form No. 10CCB, a copy of which, is placed at page 61 of the paper-book, the date of commencement of manufacturing activity is 17.06.2004 and the first year of claim of deduction under section 80IC of the Act is assessment year 2005-06. It is further evident, the assessee had undertaken expansion of the unit in financial year 2007-08 and has invested an amount of about Rs. 4 crores in plant and machinery. On a careful reading of the assessment order, it is evident, the only reason on which the Assessing Officer has rejected assessee's claim of deduction under section 80IC of the Act

    7

    is, the products manufactured by the assessee come within Schedule 13 of the Act, hence, do not fulfill the condition of section 80IC(2)(a) of the Act. The Assessing Officer has not specifically assigned any other reasons for denying assessee's claim of deduction under section 80IC of the Act. While deciding the issue in appeal, learned Commissioner (Appeals) has held that the finding of the Assessing Officer that the products manufactured by the assessee come within Schedule 13 of the Act is unsustainable in view of the decision of the Hon'ble Delhi High Court. Admittedly, against the aforesaid observation of learned Commissioner (Appeals), the Revenue has not come in appeal.

    10. Be that as it may, there is no other specific reason or observation by the departmental authorities for denial of assessee's claim of deduction under section 80IC of the Act. Of course, learned Commissioner (Appeals) has made a general observation that the assessee failed to furnish required details without specifying, what are the details required to be furnished by the assessee. Of course, one more reason learned Commissioner (Appeals) has assigned for denying assessee's claim of deduction is, on earlier assessment years the fulfillment of condition of section 80IC were not examined as the returns of income filed by the assessee were processed under

    8

    section 143(1) of the Act. From the materials placed before us, the aforesaid finding of learned Commissioner (Appeals) and the Assessing Officer are found to be not borne out from record.

    11. On the contrary, it is a fact on record that assessee's claim of deduction under section 80IC of the Act was not only examined in the first year of claim, i.e., assessment year 2005-06 but also in assessment year 2007-08, wherein, the assessment was completed under section 143(3) of the Act vide order dated 31.12.2009. A reading of the aforesaid assessment order would clearly reveal that the Assessing Officer has specifically examined the issue relating to assessee's claim of deduction under section 80IC of the Act. Thus, when assessee's claim of deduction under section 80IC of the Act was thoroughly examined in the preceding assessment years and after getting satisfied that the conditions prescribed for claiming deduction have been fulfilled, the Assessing Officer allowed the deduction claimed, such claim of deduction in a subsequent assessment year cannot be rejected without bringing any new fact and material on record, that too, purely on general observations. The decisions cited before us by learned counsel for the assessee support this view.

    9

    12. In view of the aforesaid, we hold that the disallowance of deduction claimed by the assessee under section 80IC of the Act is unsustainable. Accordingly, we direct the Assessing Officer to allow assessee's claim of deduction under section 80IC of the Act. This ground is allowed.

    13. In ground nos. 2 and 3, assessee has challenged disallowance of Rs. 55,00,000/- representing fixed assets written off and Rs.1,85,559/- representing non-payment of contribution to PF and ESI. Though, in the grounds raised, the assessee has challenged the disallowance on merits, however, at the time of hearing, the limited submission of learned counsel for the assessee is, since, the disallowances made go to increase the profits, the assessee is entitled to claim deduction under section 80IC of the Act, in respect of such enhanced profit. In this context, he drew our attention to Circular No. 37 of 2016 , dated 2ndNovember, 2016 issued by CBDT. Further, he relied upon the following decision:

    1. CIT Vs. Gem Plus Jewellery India Ltd. [2010] 233 CTR 248 (Bombay High Court)

    2. Sanghvi Jewellery Mfg. Co. (P.) Ltd. Vs. ITO [2012] 145 ttj 137 (Mumbai ITAT)

    3. ITO Vs. Anthelio Business Technologies (P.) Ltd. [2017] 78 taxmann.com 203 (Mumbai -Trib.)

    4. Patni Telecom Solutions (P.) Ltd. Vs. ITO [2013] 58 SOT 146 (Hyd.-

    ITAT)

    10

    14. Learned Departmental Representative relied upon the observations of the Assessing Officer and learned Commissioner (Appeals).

    15. Having considered rival submissions in the light of decisions relied upon, in principle, we agree with the submissions made by the learned counsel for the assessee. The disallowance made by the Assessing Officer, which are subject matter of dispute, have the effect of enhancing the profit of the assessee. That being the case, the assessee remains entitled to claim deduction under section 80IC of the Act in respect of such enhanced profit. Therefore, we direct the Assessing Officer to allow assessee's claim of deduction under Section 80IC of the Act on the aforesaid additions. Grounds are allowed.

    16. In the result, the appeal is allowed, as indicated above.

    Order pronounced in the open court on 14th July, 2022 Sd/- Sd/-

    (PRADIP KUMAR KEDIA) (SAKTIJIT DEY)

    ACCOUNTANT MEMBER JUDICIAL MEMBER

    Dated: 14thJuly, 2022. RK/-

    Copy forwarded to:

    1. Appellant

    2. Respondent

    3. CIT

    4. CIT(A)

    5. DR

    Asst. Registrar, ITAT, New Delhi

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    Comments

    M/s. Vimoni India Pvt. Ltd., New Delhi v. DCIT, New Delhi
    (Jul 14, 2022)