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Godery Phillips India Ltd Sahar Road,Chakala Andheri(E)Mumbai 99 Vs. The Addl. Commr of In come Tax 8(1)( Mumbai
October, 23rd 2012
                        IN THE INCOME TAX APPELLATE TRIBUNAL
                                 MUMBAI `G ` BENCH
                              MUMBAI BENCHES, MUMBAI

          BEFORE SHRI I P BANSAL, JM & SHRI RAJENDRA SINGH, AM
                ITA No. 7682/Mum/2010 (Assessment Year 2006-07)
                ITA No. 8549/Mum/2010 (Assessment Year 2007-08)

Godery Phillips India Ltd                  Vs     The Addl. Commr of In come Tax
Sahar Road, Chakala                               8(1)( Mumbai
Andheri (E)
Mumbai 99
              (Appellant)                                     (Respondent)

                                       &
                ITA No. 7395/Mum/2010 (Assessment Year 2006-07)


The Addl. Commr of In come Tax             Vs     Godery Phillips India Ltd
8(1)( Mumbai                                      Sahar Road, Chakala
                                                  Andheri (E)
                                                  Mumbai 99
             (Appellant)                                       (Respondent)


                             PAN No.            AABCG4768K
                     Assessee by                Shri Yogesh Thar
                     Revenue by                 Sh Amar Deep
                     Dt.of hearing              22nd Oct 2012
                     Dt of pronouncement        22nd Oct 2012


PER I P BANSAL, JM






      Appeals    nos 7682 and 7395/Mum/2010 are cross appeals and they are

directed against the order dated 18.8.2010 passed by the ld Commissioner of

Income Tax(Appeals) in respect of Assessment Year 2006-07. The appeal in ITA

No.8549/Mum/2010 is an appeal filed by the assessee and it is directed against the

order passed by the Commissioner of Income Tax(Appeals) dated 20.9.2010 for the

Assessment Year 2007-08.
                                            2
                                                                      Godery Phillips India Ltd
                                                                        ITA No. 7682/Mum/2010
                                                                        ITA No. 8549/Mum/2010
                                                                        ITA No. 7395/Mum/2010

                                                                                              .
2     Since these appeals arise certain common issues and were argued together

by both the parties; therefore, for the sake of convenience, all these appeals are

disposed off by this common order.


3     Ground of appeal read as under:


      I      ITA No. 7682/Mum/2010 (Assessment Year 2006-07) (by the assessee)


      1.     On the facts and in the circumstances of the case and in law, the Learned
      Commissioner of Income Tax (Appeals) - 16, Mumbai ("the CIT (A)") erred in
      upholding the action of the Additional Commissioner of Income Tax, Range 8(1),
      Mumbai ("A.O.") in disallowing 80% depreciation on the Uninterrupted Power Supply
      ("UPS") on the ground that, the UPS is not an energy saving device but instead an
      energy supply device.
      The Appellant prays that the depreciation of Rs 574,579/- as claimed by the
      Appellant on UPS be allowed.


      2       On the facts and in the circumstances of the case and in law, the CIT (A)
      erred in partly upholding the action of the AC by disallowing interest expenditure of
      Rs 3.03 lacs out of the total interest disallowed by the AC of Rs 6.64 lacs on the
      alleged ground that such expenditure was not incurred for the purpose of business.
       The Appellant prays that balance interest of Rs 3.03 lacs be deleted.


      3       On the facts and in the circumstances of the case and in law, the CIT (A)
      erred in partly upholding the action of the AC in disallowing an amount of Rs 25.59
      lacs on adhoc basis in respect of leave encashment expenses claimed by the
      Appellant on actual basis on the alleged ground that the said expenses would have
      been claimed in the earlier years an the basis of actuarial valuation and this amounts
      to double deduction.

      II     ITA No. 8549/Mum/2010 (Assessment Year 2007-08)(by the assessee)


      1      DISALLOWANCE OF DEPRECIATION @ 80% ON UPS AMOUNTING RS. 4,72,596/-
      On the facts and in the circumstances of the case and in law, the Learned
      Commissioner of Income Tax (Appeals) - 16, Mumbai ("the CIT (A)") erred in
      upholding the action of the Additional Commissioner of Income Tax, Range 8(1),
      Mumbai ("A.O.") in disallowing 80% depreciation on the Uninterrupted Power Supply
      ("UPS") on the ground that, the UPS is not an energy saving device but instead an
      energy storage and supply device.
      The Appellant prays that the depreciation of Rs 4,72,596/- as claimed by the
      Appellant on UPS be allowed.

      2       DISALLOWANCE OF INTEREST ON LOAN GIVEN TO SUBSIDIARIES AMOUNTING
      RS.11,34,000/-
                                            3
                                                                     Godery Phillips India Ltd
                                                                        ITA No. 7682/Mum/2010
                                                                        ITA No. 8549/Mum/2010
                                                                        ITA No. 7395/Mum/2010

                                                                                             .
      On the facts and in the circumstances of the case and in law, the CIT (A) erred in
      upholding the action of the AO in disallowing interest amounting to Rs.11,34,000/- on
      the ground that such interest was paid on the borrowings, which were given as
      interest free/subsidised loan to the subsidiaries of the Appellant.
      The Appellant prays that disallowance of interest of Rsll,34,000/- be deleted.


      3       DISALLOWANCE OF LEAVE ENCAHSMENT AMOUNTING RS. 35,83,000/-
      On the facts and in the circumstances of the case and in law, the CIT (A) erred in
      upholding the action of the AO in disallowing an amount of Rs.34,03,000/- on adhoc
      basis in respect of leave encashment expenses claimed by the Appellant on actual
      basis on the alleged ground that the said expenses would have been claimed in the
      earlier years an the basis of actuarial valuation and this amounts to double
      deduction.

      III    ITA No. 7395/Mum/2010 (Assessment Year 2006-07)(by the revenue)

      1       on the facts and in the circumstances of the case and in law, the Ld.CIT(A)
      erred in deleting the excess depreciation amounting to Rs.4,77,8401-, disallowed by
      the Assessing Officer on motor car/vehicles, without appreciating the facts and
      circumstances of the case and in law."

      2       On the facts and in the circumstances of the case and in law, th Ld.CIT(A)
      erred in reducing the disallowance made by the Assessing Officer on account of
      interest on interest free/concessional loans to subsidiary company amounting to
      Rs.6.64 lakhs, without appreciating the facts and circumstances of the case and in
      law."

4     It may be mentioned here that all the grounds raised by the assessee in

respect of Assessment Year 2007-08 are common to grounds raised in respect of

Assessment Year 2006-07. The facts relating to the Assessment Year 2006-07 will be

taken into consideration and the decision taken thereon will equally be applicable

in respect of the grounds related to Assessment Year 2007-08.


5.    Ground no.1 of assessee's appeal for the Assessment Year 2006-07 and 2007-

08 is regarding depreciation on UPS being energy saving device. It is the case of the

assessee that the UPS employed by it being an energy saving device is entitled for

higher depreciation @ 80% as against the claim of the revenue that the same is not

an energy saving device; but an energy supply device.                The impact of this

disallowance is the lesser depreciation of ` 5,74,579/- and for Assessment Year 2007-
                                            4
                                                                     Godery Phillips India Ltd
                                                                        ITA No. 7682/Mum/2010
                                                                        ITA No. 8549/Mum/2010
                                                                        ITA No. 7395/Mum/2010

                                                                                             .
08, the said amount is ` 4,72,596/-. It is the case of the ld AR that this issue is covered

by the decision of the Tribunal in assessee's own case for the Assessment Year 2002-

03 in ITA No. 2792/M/2006; for Assessment Year 2003-04 in ITA No.1071/M/2007; for

Assessment Year 2004-05 in ITA No.5569/M/2007 and for Assessment Year 2005-06 in

ITA No.6964/M/2008, copies of these orders are enclosed in the paper book at

pages 1 to 22; 23 to 47 and 48 to 67 respectively. For the sake of convenience, the

observations of the Tribunal in respect of the Assessment Year 2002-03 deciding the

issue are reproduced below:


       "13. We have heard the rival contentions. Short question is whether UPS is a
       Automatic Voltage Controller' falling within the heading of energy saving
       device in the Appendix to the Income Tax Rules 1962 giving depredation
       rates. Legislature in its wisdom has chosen to show an Automatic Voltage
       Controller' as an electrical equipment eligible for 100% depreciation, falling
       under the broader head of energy saving devices. Once Legislature deemed
       that an `Automatic Voltage Controller' is a specie falling within energy saving
       device, it is not for the Assessing Officer or Ld CIT(A) to further analyse
       whether such an Item would indeed an energy saving device. In fact it is
       beyond their powers. Hence the only question to answer, in our opinion is
       whether an UPS is an Automatic Voltage Controller'. It is mentioned in the
       product brochure (Paper Book Page 64) that the UPS automatically
       corrected low and high voltage conditions and stepped up low voltage to
       safe output levels. Thus in our opinion there cannot be a quarrel that UPS was
       doing the job of voltage controlling automatically. Even when it was
       supplying electricity at the time of power voltage, the outages remained
       controlled. Therefore in our opinion a UPS would definitely fall under the head
       of' Automatic Voltage Controller'. We are fortified in taking this view by the
       decision of Jodhpur Bench in the case of Surface Finishing Equipment (supra),
       As for the decision of Delhi Bench in the case of Nestle India Ltd. (supra)
       referred by the Ld DR, there the question was whether UPS could be
       considered as `computer' for depreciation rate of 60%. There was no issue or
       question, whether ft could be considered as an Automatic Voltage
       Controller" and hence in our opinion that case would not help the Revenue
       here. Therefore we are of the opinion that assessee was eligible for claiming
       100% depredation on UPS. Disallowance of Rs.6,82,443/- therefore stands
       deleted. Ground number 3 is allowed."
                                          5
                                                                   Godery Phillips India Ltd
                                                                     ITA No. 7682/Mum/2010
                                                                     ITA No. 8549/Mum/2010
                                                                     ITA No. 7395/Mum/2010

                                                                                           .
For other years the above decision was followed by the Tribunal.


6     After hearing both the parties, respectfully following the abovementioned

decisions of the Tribunal in assessee's own case, we decide this issue in favour of the

assessee and allow the ground no.1 of both the appeals filed by the assessee.


7     Apropos ground no2 of assessee's appeal for both Assessment Years and

ground no.2 of the revenue's appeal for Assessment Year 2006-07, the facts for

Assessment Year 2006-07 are that the assessee had advanced certain interest free

loans and loans at subsidised rates to its associated concerns, the details of which

are as under:


                    Interest free loan              ` 342.65 lacs
                    Subsidised loan (interest @ 6%) ` 1205.04 lacs

7.1   It was noticed by the Assessing Officer that the assessee had charged

interest @ 10.25% on another loan of ` 2043.41 lacs given to another 100% subsidiary

namely M/s International Tobacco Company Ltd. The Assessing Officer also noticed

that the average cost of the assessee regarding the interest on the funds borrowed

by it was @ 4.86%. It was also noticed that the interest free loans of ` 342.65 lacs to

Kashyap Metals & Allied Industries was an old loan which was prior to the insertion of

sec. 372A of the Companies Act. Noting all these facts, the Assessing Officer has

come to a conclusion that the interest free and subsidised loan, which bears interest

@ 6%, the interest receivable by the assessee, if computed at the average cost of

4.86%, then the interest which should have been received by the assessee would

amounts to ` 75.22 lacs and the assessee had received only a sum of ` 68.58 lacs.

Thus, the balance disallowance that is amounts to ` 6.64 lacs was required to be
                                            6
                                                                      Godery Phillips India Ltd
                                                                        ITA No. 7682/Mum/2010
                                                                        ITA No. 8549/Mum/2010
                                                                        ITA No. 7395/Mum/2010




                                                                                              .
made; accordingly, an amount of ` 6.64 lacs was added to the income of the

assessee.


8      Similarly for the Assessment Year 2006-07, it was noticed by the Assessing

Officer that the following loans were advanced by the assessee, being interest free

and subsidised loans:


                      Interest free loan              ` 342.65 lacs
                      Subsidised loan (interest @ 6%) ` 1543.09 lacs



8.1    The average cost of interest borne by the assessee during the Assessment

Year 2007-08 was noted to be at 4.72%. Taking the aggregate of interest free loans

and subsidised loan at ` 1,885.74 lacs, the Assessing Officer computed the interest

receivable by the assessee at ` 89 lacs and noting the fact that the assessee

received only a sum of ` 77.66 lacs, the difference of ` 11.34 lacs was added to the

income of the assessee.


8.2    In respect of Assessment Year 2006-07, the ld Commissioner of Income

Tax(Appeals) has granted part relief to the assessee on the alternative contention of

the assessee to the effect that the interest disallowance, if any, has to be calculated

according to the days of the loans advanced and in this manner, the disallowance

of ` 6.64 lacs was restricted to a sum of ` 3.61 lacs.


9      The assessee in its appeal is praying for deletion of the entire disallowance

and the revenue in its appeal is agitating the disallowance deleted by the ld

Commissioner     of   Income    Tax(Appeals).    For     Assessment   Year   2007-08,     the
                                            7
                                                                     Godery Phillips India Ltd
                                                                          ITA No. 7682/Mum/2010
                                                                          ITA No. 8549/Mum/2010
                                                                          ITA No. 7395/Mum/2010

                                                                                              .
disallowance has been upheld by the ld Commissioner of Income Tax(Appeals) in its

entirety, therefore, assessee is seeking deletion of the said addition.


10     Before us, the submissions of the ld AR is that so far as it relates to interest fee

loan of ` 342.65 lacs, it has been decided by the Tribunal in its order for Assessment

Years 2003-04 and 2004-05 that the interest on opening balance of the loans and

advances which were coming from earlier years, cannot be disallowed and such

plea of the assessee is supported by the judgment et of the Hon'ble High Court of

Karnataka in the case of Commissioner of Income-tax v. Sridev Enterprises reported

in   192 ITR 165 in which it has been held that in case of loans and advances which

were being carried forward from earlier years in which there was no disallowance,

no disallowance could be made in respect of the opening balance in the current

year as the nature and status of the advances on the first day of the current year

remained the same as the nature and status of the advances on the last day of the

preceding year. Therefore, he pleaded that to the extent it relates to ` 342.65 lacs,

no disallowance can be made as per the decision of the Tribunal in respect of

Assessment Year 2003-04 and 2004-05.


11     So far it relates to the remaining amount of ` 1205.04 lacs for Assessment Year

2006-07 and ` 1543.09 lacs for Assessment Year 2007-08, being loans on subsidised

interest rate on which the assessee charged interest @ 6% per annum, it was

submitted by the ld AR that no disallowance should be made as the average cost of

interest bearing funds is only 4.86% and 4.72 % for Assessment Year 2006-07 and 2007-

08 respectively. He has submitted that the ld Assessing Officer while making the

disallowance has included the amount of ` 342.65 in both the years and made the
                                           8
                                                                    Godery Phillips India Ltd
                                                                      ITA No. 7682/Mum/2010
                                                                      ITA No. 8549/Mum/2010
                                                                      ITA No. 7395/Mum/2010

                                                                                            .
disallowance. Therefore, the ld AR has pleaded that the disallowance sustained by

the ld Commissioner of Income Tax (Appeals) should be deleted.


11.1   On the other hand, the ld DR has relied upon the order passed by the

Assessing Officer and pleaded that the disallowance was rightly made by the

Assessing Officer    and it is wrongly deleted by the Commissioner of Income

Tax(Appeals) in respect of Assessment Year 2006-07.


12     We have heard both the parties and their contentions carefully considered.

So far as it relates to the interest pertaining to ` 342.65 lacs, the issue is covered by

the aforementioned decision of the Tribunal (consolidated order dated 20.4.2011 for

Assessment Years 2003-04 and 2004-05 copy at pages 23 to 47 of the Paper Book.)

The relevant observations of the Tribunal are reproduced below:


       "2.6.3 We have perused the records and considered the rival contentions
       carefully. The dispute is regarding disallowance of interest paid by the
       assessee on account of advances given to the subsidiary of the assessee
       company. The assessee had advanced interest free loan of Rs.342.65 lacs, It
       had also advanced further loans at concessional rate. The assessee had also
       made borrowings on which substantial interest was being paid. The authorities
       below have disallowed part of the interest proportionate to interest free
       advances and advances given on concessional rate on the ground that
       there was no material to show that the loans taken by the assessee were used
       wholly and exclusively for the purpose of business or that these loans and
       advances were given out of own funds. The case of the assessee is that the
       interest free advances had been given since financial year 1992-93 and loans
       on concessional rate had been given from financial year 1998-99. These had
       been given out of own funds as the assessee had sufficient interest free funds
       and profit earned during the relevant years Reliance has been placed on the
       judgment of Hon'ble High Court of Mumbal in case of Reliance Utilities and
       Power (supra). It has also been argued that most of the loans/ advances
       were coming from the earlier years in which there were no disallowances and
       therefore no disallowance could be made in respect of opening balances.
       The assessee has also raised plea of commercial expediency on the ground
       that loans and advances had been given to the concern which was a 100%
       subsidiary of the assessee company and therefore the same had to be
       treated for the purposes of business of the assessee.
                                          9
                                                                  Godery Phillips India Ltd
                                                                     ITA No. 7682/Mum/2010
                                                                     ITA No. 8549/Mum/2010
                                                                     ITA No. 7395/Mum/2010

                                                                                          .
       2.6.4 We have carefully considered the various aspects of the matter. We find
       substance in the submission of the assessee that no disallowance could be
       made in respect of the opening balances of loans and advances which were
       coming from earlier years and in which there were no disallowance. The plea
       of the assessee is supported by the judgment of Hon'ble High Court of
       Karnataka in case of Sridev Enterprises (supra) in which it was held that in
       case loans and advances were being carried forward from earlier years in
       which there was no disallowance, no disallowance could be made in respect
       of the opening balance in the current year as the nature and status of the
       advances on the first day of the current year remained the same as the
       nature and status of the advances on the last day of preceding year. In the
       earlier year there were no disallowances which meant that the revenue was
       satisfied that loans and advances were give from own funds. Therefore
       respectfully following the judgment of Hon'ble High Court of Karnataka in
       case of Sridev Enterprises (supra) we hold that no disallowance of interest will
       be made in respect of the opening balances as on the first day of assessment
       year involved."




13     Now the question remains in respect of subsidised loan advanced by the

assessee to its sister concerns on which interest @ 6% has been charged.


13.1   A categorical finding has been given by the Assessing Officer that the

average interest cost for the Assessment Year 2006-07 and 2007-08 are 4.86% and

4.72 % respectively. The assessee had charged @ 6% interest from its subsidiary;

therefore, the assessee has charged more interest rate than the average interest

rate borne by it on interest bearing funds.    Therefore, there is no justification for

making any addition, finding force in such contention of the assessee; we delete

the entire addition for both the years. Therefore, ground no. 2 of both the appeals of

the assessee are allowed and ground no.2 of revenue's appeal for Assessment Year

2006-07 is dismissed.


14     Ground no.3 of the assessee's appeal for both the years relates to

disallowance made on account of leave encashment.
                                            10
                                                                     Godery Phillips India Ltd
                                                                        ITA No. 7682/Mum/2010
                                                                        ITA No. 8549/Mum/2010
                                                                        ITA No. 7395/Mum/2010

                                                                                             .
15     It is submitted by the ld AR that this issue requires to be set aside to the file of

the Assessing Officer as in earlier years, similar issue has been set aside by the

Tribunal in respect of AYs 2003-04, 2004-05 and 2005-06. Reference in this regard was

made to the order of the Tribunal in respect of Assessment Year 2003-04 and 2004-05

in ITA No. 1071/M/2007 and 5569/M/2007 copy of such order is placed at pages 23

to 47 and in ITA No.6964/M/2008 at pages 48 to 67 of the paper book.


15.1   For the sake of convenience, the observations of the Tribunal in Assessment

Year 2004-05 ass given in para 2.8.1 are reproduced as under:


       "2.8.1 We have heard both the parties, perused the records and considered
       the matter carefully. The dispute is regarding disallowance of part of the
       claim relating to leave encashment. The assessee had been making the
       claim earlier on the basis of actuarial valuation but consequent to the
       amendment of section 438 the claim was being made on payment basis from
       A.Y.2003-04. The Assessing Officer has made estimated disallowance out of
       the claim made on payment basis on the ground that part of the payments
       made may relate to earlier year when these were allowed on actuarial basis.
       The Assessing Officer has made disallowance on estimate which cannot be
       sustained. Only the payment which had actually been allowed earlier can be
       disallowed. In - our view matters require fresh examination and disallowance
       has to be restricted to the amounts allowed in the earlier year. We therefore
       set aside the order of CIT(A) and restore the issue to the file of Assessing
       Officer for passing a fresh order after necessary examination and after
       allowing opportunity of hearing to the assessee."

For Assessment Year 2005-06, the aforesaid decision has been followed


15.2   It was submitted by the ld AR of the assessee that similar directions may be

issued for these years also.


15.3   On the other hand, the ld DR has relied upon the order passed by the

Assessing Officer


16     After hearing both the parties, we find that this issue is covered by the

abovementioned decisions of the Tribunal.         Therefore, respectfully following the
                                           11
                                                                    Godery Phillips India Ltd
                                                                      ITA No. 7682/Mum/2010
                                                                      ITA No. 8549/Mum/2010
                                                                      ITA No. 7395/Mum/2010

                                                                                            .
decisions of the Tribunal, we restore the issue to the file of the Assessing Officer with

similar directions.


17     For statistical purpose, ground no.3 of the assessee's appeal for both the

years is considered to be allowed.


18     In the result, the appeals filed by the assessee are partly allowed in the

aforesaid manner whereas the appeal of the revenue is dismissed.


Order pronounced in the open Court by this 22nd day of Oct 2012.


               Sd/-                                                Sd/-

          ( RAJENDRA SINGH    )                             ( I P BANSAL )
            Accountant Member                             Judicial Member

Place: Mumbai : Dated: 22nd Oct 2012
Raj*
Copy forwarded to:

1      Appellant
2      Respondent
3      CIT
4      CIT(A)
5      DR


                                      /TRUE COPY/
                                        BY ORDER

                                   Dy /AR, ITAT, Mumbai
 
 
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