Citation Codes

Equivalent Citations

citation codes

Case Number

MA 117/BANG/2022

Disposition

allowed

Advocates

Acts

FINANCE ACT 2016
SECTION 254 INCOME TAX ACT 1961
INCOME TAX ACT
ARTICLE 141 CONSTITUTION OF INDIA
provisions of section 254 (2) by Finance Act. 2016
u/s 254(2) of the Income-tax Act,1961 ['the Act'

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Smart Summary

Summary of the Income Tax Appellate Tribunal Order in MP No.117/Bang/2022 (M/s. Sunrise Freight Movers P. Ltd.)

Factual and Procedural Background

This miscellaneous petition (MP No.117/Bang/2022) was filed by the Revenue under section 254(2) of the Income-tax Act, 1961 seeking rectification of the Tribunal's order in ITA No.613/Bang/2021 dated 22.3.2022. In the impugned order dated 22.3.2022 the Tribunal had held that the Revenue authorities were not justified in disallowing a sum of Rs.1,83,582 on account of delayed payment of employees' contributions to ESI and PF by invoking section 36(1)(va) of the Act, where that payment, though delayed beyond the due date under the relevant Acts, was made within the due date for filing the return of income under section 139(1).

The Revenue's miscellaneous petition sought to reverse the Tribunal's order and to hold that the disallowance under section 36(1)(va) was fully justified. The Revenue relied principally on the Supreme Court's decision in Checkmate Services Pvt. Ltd. vs. CIT-1 (Civil Appeal No.2833/2016, judgment dated 12 October 2022), which addressed the treatment of delayed employee PF contributions under the Income-tax Act and distinguished the rules for employee versus employer contributions (s.36(1)(va) versus s.43B(b)).

A preliminary procedural dispute arose about limitation: the assessee's representative argued the miscellaneous application was time-barred (order passed 22.3.2022; MA filed 31.10.2022; six-month period from end of March would expire 30.9.2022), while the departmental representative argued the limitation period runs from the date of communication of the order to the Revenue (which was 25.4.2022), and therefore the application filed on 31.10.2022 was within time.

Legal Issues Presented

Whether the time limit for filing an application under section 254(2) (six months from the end of the month in which the order was passed) is to be reckoned from the date the Tribunal's order was passed or from the date on which the order was communicated to the affected party (here, the Revenue).
Whether a subsequent decision of the Hon'ble Supreme Court (Checkmate Services Pvt. Ltd.) which was rendered after the Tribunal's order constitutes a "mistake apparent from the record" such that the Tribunal may rectify its earlier order under section 254(2).
Whether the disallowance of employees' PF/ESI contributions under section 36(1)(va) of the Act is justified when the payment was made after the statutory due date prescribed in the respective Acts but within the due date for filing the return under section 139(1) (i.e., the substantive question of allowability vis-à-vis the distinction between sections 36(1)(va) and 43B).

Arguments of the Parties

Revenue's Arguments (Applicant)

The Tribunal's order dated 22.3.2022 should be rectified under section 254(2) because the Supreme Court's decision in Checkmate Services Pvt. Ltd. (rendered on 12 October 2022, after the Tribunal's order) clarifies that delayed employees' contributions are permanently barred from deduction under section 36(1)(va), and hence the original order failed to apply the correct law.
The miscellaneous application was filed within time because the order of 22.3.2022 was communicated to the Revenue (Principal CIT, Bengaluru) by hand on 25.4.2022, and the six‑month period under section 254(2) should be counted from the end of the month in which the order was communicated.

Assessee's Arguments (Respondent / Appellant in ITA)

The miscellaneous application is time‑barred. The statutory six‑month period for filing an application under section 254(2) runs from the end of the month in which the order was passed (22.3.2022), so the last date was 30.9.2022; the Revenue filed on 31.10.2022 and the application must therefore be dismissed in limine.
Implicit in the Tribunal's original order: the assessee relied on the view that payment within the return‑filing due date under section 139(1) was sufficient (at least insofar as employer's contribution treatment under s.43B is concerned); the Tribunal originally accepted that position for the facts before it.

Table of Precedents Cited

Precedent	Rule or Principle Cited For	Application by the Court
Checkmate Services Pvt. Ltd. vs. CIT-1 (Civil Appeal No.2833/2016) — Judgment dated 12.10.2022 (Supreme Court)	The decision distinguishes treatment of delayed employees' PF contribution (subject to s.36(1)(va)) and employer's contribution (subject to s.43B(b)). It holds employee contribution must be paid by the due dates prescribed in the respective Acts and failure to do so negates deduction under s.36(1)(va); employer's contribution delayed may be governed by s.43B and its payment basis.	The Tribunal treated this subsequent Supreme Court decision as authoritative law that created a mistake apparent from the record in the Tribunal's earlier order and used it as the primary basis to rectify the order and hold the disallowance justified.
Pawan Kumar Jain vs. Dy. CIT (2013) 155 TTJ 14 (Mumbai Tribunal)	For purposes of filing an application under section 254(2) (pre-amendment), the limitation period should start from when the order under s.254(1) is communicated to the assessee and not from the date the order was passed.	The Tribunal cited this decision as authority supporting the proposition that the limitation period should be calculated from the date of communication; it formed part of the reasoning admitting the Revenue's MA as within time.
Srinivas Sashidhar Chaganty vs. ITO (Hyd. ITAT — "A" Bench — M.A. No.05/Hyd/2017 arising in ITA No.1420/Mum/2015 dated 12.7.2017)	The Hyderabad Tribunal, considering the provisions after amendment by Finance Act 2016, took a contrary view to Pawan Kumar Jain (i.e., it held differently on when limitation should be reckoned).	The Court acknowledged this conflicting authority (described as diametrically opposite to Pawan Kumar Jain) but did not adopt it; rather it considered other authorities and principles in favour of reckoning limitation from communication.
Vijay Kumar Ruia vs. CIT (2011) 334 ITR 38 (Allahabad High Court)	The expression "from the date of the order" for limitation purposes should be construed to mean the date of communication or knowledge of the order; limitation runs from the date the aggrieved party knew of the order, consistent with principles of fair play.	The Tribunal relied on this High Court authority to support the proposition that the six‑month period in s.254(2) should be reckoned from the end of the month in which the order was communicated to the party (here, the Revenue).
CIT vs. Saurashtra Kutch Stock Exchange — 219 CTR (SC) 90 (Supreme Court)	Non-consideration of the decision of the jurisdictional High Court or the Supreme Court can constitute a "mistake apparent from the record" and thus be rectified under section 254(2) (or analogous rectification provision).	The Tribunal invoked this holding to justify that failure to apply the later Supreme Court authority (Checkmate) in the earlier order amounted to a rectifiable mistake apparent from the record.
Honda Siel Power Products Ltd. v. CIT — 295 ITR 466 (Supreme Court)	Explains the scope of rectification powers under section 254(2): the Tribunal can rectify mistakes apparent from the record to prevent prejudice resulting from its own omission or oversight; rectification is not an exercise of inherent review but correction of manifest error where prejudice resulted.	The Tribunal applied this explanation of scope to conclude that it was justified to rectify its earlier order once it was pointed out that the Supreme Court's ruling (Checkmate) had not been applied and caused prejudice.

Court's Reasoning and Analysis

The Tribunal proceeded in two analytical stages: first, it addressed the preliminary question of limitation; second, it considered the merits and whether rectification under section 254(2) was permissible.

Limitation analysis:

The Tribunal quoted the text of section 254(2) (six months from the end of the month in which the order was passed) and observed that there are judicial authorities taking different views about whether the limitation runs from the date of the order or from the date of communication/knowledge of the order.
It reviewed the Mumbai Tribunal decision in Pawan Kumar Jain (which supported reckoning limitation from communication) and the conflicting Hyderabad Tribunal decision in Srinivas Sashidhar Chaganty (which took a contrary view). It also considered the Allahabad High Court decision in Vijay Kumar Ruia, which interpreted "date of the order" as meaning date of communication or knowledge of the order, invoking principles of fair play and the need for notice before remedies can reasonably be exercised.
On balance, and applying these authorities and principles, the Tribunal concluded that the six‑month period under section 254(2) should be reckoned from the end of the month in which the order was communicated to the party exercising the right to apply for rectification. It found the Revenue had been served by hand on 25.4.2022; consequently the MA filed on 31.10.2022 (received 25.4.2022) was within time and was admitted for adjudication.

Merits / Rectification analysis:

The Tribunal considered whether the failure to apply the law as declared by the Hon'ble Supreme Court in Checkmate (rendered after the Tribunal's order) amounted to a "mistake apparent from the record" capable of rectification under section 254(2).
It relied on the Supreme Court's guidance in CIT vs. Saurashtra Kutch Stock Exchange and Honda Siel Power Products Ltd. to explain the object and ambit of rectification power: where a Tribunal's order has a manifest error or omission that causes prejudice, rectification is proper to correct that mistake; such rectification is consistent with the duty to avert prejudice caused by the Tribunal's own oversight and does not amount to an inherent review.
The Tribunal also invoked the constitutional principle (Article 141) that decisions of the Supreme Court are binding on all courts, and that the law declared by the Supreme Court operates retrospectively unless the Court specifies otherwise.
Applying these principles, the Tribunal held that the subsequent Supreme Court decision in Checkmate constituted binding law which the earlier Tribunal order had not applied; that omission therefore constituted a mistake apparent from the record warranting rectification under section 254(2).
On this basis the Tribunal concluded that the disallowance under section 36(1)(va) was in fact justified; the earlier Tribunal order was modified/rectified accordingly and the assessee's appeal was dismissed.

Holding and Implications

Holding: The miscellaneous petition filed by the Revenue under section 254(2) of the Income-tax Act is ALLOWED. The Tribunal admitted the MA as within time (reckoning limitation from communication of the order, which occurred on 25.4.2022) and, on the merits, rectified its earlier order to hold that the disallowance under section 36(1)(va) was justified in view of the Supreme Court's decision in Checkmate Services Pvt. Ltd. Consequently, the assessee's appeal in ITA No.613/Bang/2021 stood dismissed and the Tribunal's order was modified/rectified.

Implications:

Direct effect: The Revenue's application for rectification succeeded; the assessee's appeal was dismissed and the disallowance of Rs.1,83,582 on account of delayed employees' PF/ESI contribution was held to be properly disallowed under section 36(1)(va).
Rectification basis: The Tribunal treated a subsequently rendered Supreme Court decision as creating a mistake apparent from the record when the earlier Tribunal order failed to apply the law so declared, and therefore amenable to correction under section 254(2).
Broader precedent: The order applies established principles (Supreme Court authorities cited) about the scope of rectification powers and the binding nature of Supreme Court decisions. The opinion does not purport to announce a new legal doctrine beyond applying those authorities to the facts; its direct consequence is rectification of the Tribunal's own prior order for the parties before it.

Order pronounced in open court on 30th November 2022.

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The Additional Director of Income Tax, CPC, Bengaluru v. Sunrise Freight Movers Private Limited, Bengaluru

MP No.117/Bang/2022 M/s. Sunrise Freight Movers P. Ltd., Bangalore

IN THE INCOME TAX APPELLATE TRIBUNAL

"B'' BENCH: BANGALORE

BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER

AND

SMT. BEENA PILLAI, JUDICIAL MEMBER

M.P. No.117/Bang/2022 (Arising out of ITA No.613/Bang/2021) Assessment Year: 2019-20

The ACIT

Circle-6(1)(1)

Bangalore

Vs.

M/s. Sunrise Freight Movers Pvt. Ltd.

No.10, PID, 48-34-10, 2^ndFloor, 1^stCross

Lalbagh Road

Bangalore 560 052.

PAN NO : AAFCS1371Q

APPELLANT RESPONDENT

Appellant by : Shri R.E. Balasubramaniyan, A.R.

Respondent by : Shri K.R. Narayana, D.R.

Date of Hearing : 25.11.2022

Date of Pronouncement : 30.11.2022

O R D E R

PER CHANDRA POOJARI, ACCOUNTANT MEMBER:

This miscellaneous petition filed by the revenue u/s 254(2) of the Income-tax Act,1961 ['the Act' for short] seeking rectification of order of the Tribunal in ITA No.613/Bang/2021 dated 22.3.2022.

2. In the aforesaid order dated 22.3.2022, the Tribunal held that the Revenue authorities were not justified in making a disallowance on delayed payment of employee's contribution to ESI and PF of Rs.1,83,582/- made by the assessee beyond the due date by invoking

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the provisions of section 36(1)(va) of the Act, but within the due date for filing return of income u/s.139(1) of the Act. On the above issue, it is not disputed that as per the decision of the Hon'ble Supreme Court rendered in the case of CHECKMATE SERVICES PVT LTD VS CIT-1 in CIVIL APPEAL 2833/2016 vide its judgment dated 12 October 2022 decided the issue on allowability/treatment of 'delayed' Employee PF Contribution payment in hands of assessee under provisions of Income Tax Act and held that Section 36(1)(va) and Section 43B(b) operate on totally different equilibriums and have different parameters for due dates, i.e., employee's contribution is linked to payment before the due dates specified in the respective Acts and employer's contribution is linked to the payment before the prescribed due date for filing of return u/s. 139(1) of the Act. The result of any failure to pay within the prescribed dates also leads to different results. In the case of employee's contribution, any failure to pay within the prescribed due date under the respective PF Act or Scheme will result in negating employer's claim for deduction permanently forever u/s.36(1)(va) of the Act. On the other hand, delay in payment of employer's contribution is visited with deferment of deduction on payment basis u/s.43B of the Act and is therefore not lost totally. Therefore, as per the above decision, the disallowance made by the Revenue authorities, were fully justified.

2.1. Through this miscellaneous petition, the revenue seeks an order to reverse the order of the Tribunal dated 22.3.2022 and hold that the disallowance of deduction by the revenue authorities u/s.36(1)(va) of the Act is fully justified and dismiss the appeal of the Assessee.

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3. At the time of hearing, the Ld. A.R. made primary objection that the miscellaneous petition filed by the revenue is barred by time as the order was passed on 22.3.2022 and the revenue filed the miscellaneous petition on 31.10.2022. According to the ld. AR, time limit to file MA u/s 254(2) of the Act is within 6 months from the end of the month in which the order was passed. As such, the order was passed in this case was on 22.3.2022 and time limit to file MA u/s 254(2) of the Act will expire 6 months from the end of the month of March, 2022 i.e. 30.9.2022 and in the present case, since the MA has been filed by the revenue only on 31.10.2022, which is time barred and the same is to be dismissed in limine.

4. On the other hand, ld DR submitted that in this case, the order dated 22.3.2022 has been served on department i.e. Principal CIT, Bengaluru, only on 25.4.2022 by hand and the period of limitation for filing application u/s 254(2) of the Act, would start from the point of time when the order u/s 254(1) of the Act is communicated to the assessee and not from the date of passing of the order. He submitted that once the date of communication of order has been considered in the place of date of passing of the order, consequently, the period of 6 months is to be reckoned from the end of the month in which the order was communicated to the assessee to be considered. As such, the revenue has filed the MA on 31.10.2022 is within the time limit and it is to be considered for adjudication.

5. We have heard the rival submissions and perused the materials available on record. Admittedly, the order in this case has been passed on 22.3.2022 and it has been communicated to the assessee on 20.4.2022 by RPAD and to the revenue it was served by hand on 25.4.2022 on PCIT, Bengaluru. Now the question is whether the time limit to file application u/s 254(2) of the Act is to be reckoned

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from the date of passing of the order or from the date of communication of order to the revenue authorities. For this purpose, we go through the provisions of section 254(2) of the Act, which reads as under:-

"The appellate may, at any time within 6 months from the end of the month in which the order was passed, with a view to rectifying any mistake apparent from the record, amend in order passed by it under sub section (1), and shall make such amendment if the mistake is brought to its notice by the assessee or AO."

5.1 A bare perusal of the above provisions shows that either parties can file application for rectification of order passed u/s 254(1) of the Act within a period of 6 months from the end of the month in which the order was passed. In the present case, the order was passed on 22.3.2022 and according to the ld. A.R., the time limit to file MA u/s 254(2) of the Act expires on 30.9.2022 and there was delay in filing this miscellaneous petition and hence, it is to be dismissed.

5.2 In context of the provisions of section 254(2) of the Act (as prior to its amendment by Finance Act, 2016 w.e.f. 1.6.2016) the Mumbai Tribunal has in Powan Kumar Jain vs. Dy. CIT (2013) 155 TTJ 14 (Mum-Tribunal), held that for purposes of filing application u/s 254(2) of the Act, the period of limitation would start from the point of time when order u/s 254(1) is "communication to the assessee"

and not from the "date of the passing of the order".

In coming to this decision, the Mumbai Tribunal has noted as:

"From the principles and maxims laid down by the Hon 'ble Supreme Court in catena of cases as referred to above, it is amply clear that the "date of order" should be construed and reckoned with the date of knowledge of the order i.e., when the order has been communicated to the pacify. The legal maxim behind this is, how a person concerned or a person aggrieved is expected to exercise the right of remedy conferred by the Statute, unless the order is communicated or known to him either actual or constructively. The underlying principles is of fair play and recognition of legal rights of remedy in a constructive manner and not to give any construction or interpretation

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so as to defeat the purpose for which the legal remedy has been enacted in the provisions relating to limitations. It iso fundamental principle of justice and fair play that parties, whose rights are affected by an order must have a knowledge or notice of it, otherwise, the legal rights to remedy is lost to the party, even when he is not at fault."

5.3 However, in a recent decision, the Hyderabad Tribunal in miscellaneous application proceedings u/s 254 (2) in the case of Srinivas Sashidhar Chaganty vs. ITO ( Hyd. ITAT — "A" Bench — M.A. no. 05/Hyd/2017 arising in ITA no. 1420/Mum/2015 dated 12-7-2017 for Assessment Year 2007-08 — reported in www.itatonline.org) in context of the subsequently amended provisions of section 254 (2) by Finance Act. 2016 w.e.f. 1-6-2016 has held diametrically the opposite of what the Mumbai Tribunal held in the case of Pawan Kumar Jain (supra). In the case before it, order u/s 254 (1) was passed / pronounced on 21-06-2016 and from the end of this month (June 2016), the period of six months ended on 31-12-2016. The case of the assessee was that order u/s 254 (1) was served on him on 05-07-2016 and if this date is considered. the miscellaneous application filed on 20-01-2017 was within time and maintainable.

5.4 However, the Hon'ble Allahabad High Court in the case of Vijay Kumar Ruia Vs. CIT (2011) 334 ITR 38 (Allahabad) in the decision concerned in an appeal preferred by the assessee under Rule 86 of recovery proceedings in Schedule II of the Act. The rule prescribed that the appeal must be preferred by the assessee within 30 days of the order passed by the Tax Recovery Officer. The question before the High Court was whether words "date of the order" in Rule 86 should be construed as "date of service or communication of the order" to the assessee?

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The Allahabad High Court held as under —

"The second point of determination is as to whether the limitation for filing the appeal would run from the actual date of the order or from the date of service of the order and, consequently as to whether the appeal is barred by limitation. There is no dispute to the fact that the order confirming the sale was passed on 25-4-1988 and the sale certificate was also issued on the same day. The appeal was presented under rule 86 on 19-9-1988. The limitation for filing the appeal under rule 86(2) is 30 days from the date of the order'. Thus, the appeal apparently appears to be beyond time by 117 days. However, the argument is that the limitation for filing the appeal would start running from the date when the order was served and the date of service of the order would be recognised as the date of the order.

Generally speaking, judicial and quasi-judicial orders are required to be passed in the presence of the parties or their representatives and where parties or their representatives are not present, normally the orders are communicated, especially where the order is appealable or revisable so as to enable the party to avail of the remedy so provided. Therefore, communication and knowledge of the order passed is necessary and in consonance with the principles of fair play. If the party aggrieved is not made aware of the order it cannot be expected to take recourse to the remedy available against it. Therefore, the fundamental principle is that the party whose rights are affected by any order must have the knowledge of the order.

Thus, it can be said that for the purposes of calculating limitation the expression 'from the date of the order', is to be construed to mean 'the date of communication or knowledge of the order'. In the instant case, the date of knowledge of the order, according to the petitioner is 18-8-1988 and the date of actual service and communication undisputedly happens to 29-2-1988. The appeal was preferred on 19-9- 988. On 18-9-1988 there was a holiday. Thus, the appeal was within limitation both from the date of knowledge of the order and its service. In this view of the matter, the appellate authority manifestly erred in law in dismissing the appeal as barred by time."

5.5 In view of the above precedents, in our opinion, the time limit to file a miscellaneous petition u/s 254(2) of the Act to rectify the order of the Tribunal passed u/s 254(1) of the Act is to be considered is within 6 months from the end of the month in which the order was communicated so as to rectify the mistake passed u/s 254(1) of the Act. Accordingly, we admit the miscellaneous petition filed by the revenue as the miscellaneous petition has been filed on 31.10.2022

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as it was received only on 25.4.2022 by the revenue authorities and in our opinion, miscellaneous petition filed in this case is within time limit allowed u/s 254(2) of the Act and the same is admitted for adjudication.

5.6 Coming to the merit of the issues raised by the revenue in its miscellaneous petition, we not that Hon'ble Supreme Court in the case of CIT Vs. Saurashtra Kutch Stock Exchange case 219 CTR (SC) 90 has held that non-consideration of the decision of the jurisdictional high court/Supreme Court constitutes mistake apparent from record and is rectifiable within the meaning of section 254(2) of the Act. In Honda Siel Power Products Ltd. v. CIT 295 ITR 466, the Hon'ble Supreme Court explained the scope of rectification powers u/s/254(2) of the Act, as follows:

"Scope of the Power of Rectification

12. As stated above, in this case we are concerned with the application under section 254(2) of the 1961 Act. As stated above, the expression

"rectification of mistake from the record" occurs in section 154. It also finds place in section 254(2). The purpose behind enactment of section 254(2) is based on the fundamental principle that no party appearing before the Tribunal, be it an assessee or the Department, should suffer on account of any mistake committed by the Tribunal. This fundamental principle has nothing to do with the inherent powers of the Tribunal. In the present case, the Tribunal in its Order dated 10.9.2003 allowing the Rectification Application has given a finding that Samtel Color Ltd. (supra) was cited before it by the assessee but through oversight it had missed out the said judgment while dismissing the appeal filed by the assessee on the question of admissibility/allowability of the claim of the assessee for enhanced depreciation under section 43A. One of the important reasons for giving the power of rectification to the Tribunal is to see that no prejudice is caused to either of the parties appearing before it by its decision based on a mistake apparent from the record.

13. "Rule of precedent" is an important aspect of legal certainty in rule of law. That principle is not obliterated by section 254(2) of the Income-tax Act, 1961. When prejudice results from an order attributable to the Tribunal's mistake, error or omission, then it is the duty of the Tribunal to set it right. Atonement to the wronged party by the court or Tribunal for the wrong

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committed by it has nothing to do with the concept of inherent power to review. In the present case, the Tribunal was justified in exercising its powers under section 254(2) when it was pointed out to the Tribunal that the judgment of the coordinate bench was placed before the Tribunal when the original order came to be passed but it had committed a mistake in not considering the material which was already on record. The Tribunal has acknowledged its mistake, it has accordingly rectified its order. In our view, the High Court was not justified in interfering with the said order. We are not going by the doctrine or concept of inherent power. We are simply proceeding on the basis that if prejudice had resulted to the party, which prejudice is attributable to the Tribunal's mistake, error or omission and which error is a manifest error then the Tribunal would be justified in rectifying its mistake, which had been done in the present case."

5.7. Article 141 of the Constitution of India provides that the law declared by Hon'ble Supreme Court shall be binding on all courts within the territory of India. The law laid down by Supreme Court operates retrospectively and is deemed to the law as it has always been unless, the Supreme Court, says that its ruling will only operate prospectively.

5.8 In the light of the law as explained above, there is a mistake apparent on record in view of the decision of the Hon'ble Supreme Court in the case of Checkmate Services Pvt.Ltd. (supra) though rendered subsequent to the order passed by the Tribunal and has to be rectified by holding that the disallowance made by the revenue authorities u/s.36(1)(va) of the Act was justified. Consequently, the appeal by the Assessee will stand dismissed. The order of the Tribunal will stand modified /rectified accordingly.

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6. In the result, the miscellaneous petition filed by the revenue stands allowed.

Order pronounced in the open court on 30^thNov, 2022

Sd/- (Beena Pillai) Judicial Member Sd/-

(Chandra Poojari) Accountant Member

Bangalore, Dated 30^thNov, 2022. VG/SPS

Copy to:

1. The Applicant

2. The Respondent

3. The CIT

4. The CIT(A)

5. The DR, ITAT, Bangalore.

6. Guard file By order

Asst. Registrar, ITAT, Bangalore.

The Additional Direc... v. Sunrise Freight Move...