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The Godavari Sugar Mills Ltd. 45-47, Somaiya Bhavan, M.G. Road, Fort, Mumbai 400 001. Vs. Additional CIT Range 2(1), Mumbai.
October, 23rd 2015
   IN THE INCOME TAX APPELLATE TRIBUNAL "G" BENCH, MUMBAI


          BEFORE AMIT SHUKLA, JUDICIAL MEMBER AND
          SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER
                              ITA NO 2220/Mum/2010
                             Assessment year: - 2002-03
     The Godavari Sugar Mills Ltd.       v.     Additional CIT
     45-47, Somaiya Bhavan,                     Range 2(1),
     M.G. Road,                                 Mumbai.
     Fort,
     Mumbai ­ 400 001.
     PAN/GIR No.   AAACT5004A
     Appellant                                       Respondent

            Assessee By            Shri Vipul Joshi & Shri Nishit Gandhi
            Revenue By             Shri Vikash Kumar Agarwal


           Date of hearing                    13.08.2015
           Date of pronouncement              21.10.2015



                                      ORDER

Per Ramit Kochar, Accountant Member

     This appeal by the assessee is directed against the order dated
12.01.2010 of Commissioner of Income Tax (appeals) for assessment year
2002-03. The assessee has raised following grounds of appeal:-
                                      2

                                               ITA NO 2220/Mum/2010
                                             Assessment year: - 2002-03


     "1. The Ld. Commissioner of Income Tax (Appeals) dismissed the claim of
     Appellants in the matter of depreciation claim of Rs. 4,70,784 on certain Plant &
     Machinery, Furniture & fixtures, Office equipments, which the Assessing Officer
     had taken under different heads and with different amounts. The Appellant submit
     that the CIT (A) ought to have properly considered and appreciated the
     explanation rendered by the Appellants.

     2. The Ld. CIT (A) has dismissed the Appellants' claim by disallowing Rs.4,00,200/-
     representing the amount paid as stamp fees for the agreement pertaining to the
     Co- Gen project in respect of the agreement entered into for US grant/aid.

     3. The CIT (A) erred in confirming of charging of Rs. 19,37,524 under Sec. 41 m
     respect of sundry credit balance written off by the Appellant unilaterally.

     4. The Ld. CIT (A) 'has erred in dismissing the Appellants' claim for additional
     sugar cane price of Rs. 1,14,59,037 which the Appellant had claimed on the basis of
     purchase of sugar cane. The Ld. CIT (A) disallowed the claim stating that the same
     has crystallized in the previous year 2004-05 relevant to Assessment Year 2005-06
     and he further erred in stating that the same is to be allowed in the Assessment
     Year 2005-06 on merits.

     The Ld. CIT (A) has erred in dismissing the Appellants' claim u/s 80HHC
     Considering the Assessee's income as assessed under book profit u/s 115JB. The Ld.
     CIT (A) has erred in following formulations in the case of CIT vs Ajanta Pharma
     (223 ITR 441 (2009)(Bombay) ."



2.   Ground No. 1 is regarding depreciation of Rs. 417784/- on
depreciation on account of addition made during the year between as per
block of assets as per companies Act and block of asset as per Income Tax
Rules.




                                                                     Page 2 of 17
                                   3

                                         ITA NO 2220/Mum/2010
                                       Assessment year: - 2002-03
3.   It was observed by the Assessing Officer that fixed assets of block of
assets as per Companies Act on sugar division as well as chemical division
and the statement of depreciation claimed as per income tax and there
difference between two on account of addition of assets made in certain
asset during the year as under:-


Division    Addition made      Cost of assets   Addition         Cost of assets
            in the fixed       addition    is   made in the      addition
            assets as per      made (Rs. in     statement of     made (Rs.)
            Companies Act      lakhs)           fixed assets
                                                (i.e. block of
                                                assets ) as
                                                per I.T. Act
Sugar       Plant          & 651.29             Plant        &   67402311
            Machinery                           Machinery
Chemical    Furniture      & 49.32              Furniture &      6798026
            fixture                             fixture
                                                                 74200519



4.   In reply the assessee submitted that in books of accounts addition to
office equipment of Rs. 22,63,535/- was considered under "Furniture"
while for the claim under the Income Tax Rules, the same is considered as
"Machineries". The AO observed that the assets like ceiling fans, fire
extinguisher, AC etc. Assessee company has not explained the difference
properly along with the supporting evidence and hence there is a


                                                             Page 3 of 17
                                    4

                                            ITA NO 2220/Mum/2010
                                          Assessment year: - 2002-03
difference on account of plant & machinery of Rs. 22,73,311/- and in
difference in furniture & fixture of Rs. 18,66,208/- respectively, which is
not explained properly. AO disallowed depreciation by observing as
under:-
     "i)   Difference in plant & machinery of Rs. 22,73,311/- @ 12.5% (less than
           180 days depreciation works out to Rs. 284,164/-
     ii)   Difference in furniture and fixture of Rs. 1,86,620/- @ 10% (i.e. more
           than 180 days) depreciation works out to Rs. 1,86,620/-.

     Thus, the total depreciation on the difference of plant & machinery and
     furniture works out to Rs. 4,70,784/-. Accordingly, the same is disallowed and
     deducted from the total depreciation claimed."


5.   Aggrieved, the assessee carried the matter in appeal before CIT(A).

6.   The assessee submitted before the CIT(A) that the difference in plant
& machinery has been wrongly taken at Rs. 22,73,311/- as against Rs.
22.64 lacs. He submitted that there certain items which under the
companies Act classified as furniture & fixture and equipments but under
the Income Tax Act they are treated as plant & machinery. The Ld. AR duly
filed the reconciliation statement as under:-

Division         Item              Addition as per Addition as per
                                   books           Tax Audit Report
Sugar Division Furniture & Fixture 651.29          651.29
               Add: Furniture &                    22.64
               Fixture   as    per
               accounts

                                                                 Page 4 of 17
                                    5

                                              ITA NO 2220/Mum/2010
                                           Assessment year: - 2002-03
                                                               673.93
Chemical       Furniture & Fixture        49.32                    49.32
division       Less : Plant &                                  (-) 22.63
               Machinery as per
               I.T. Act
               (A)                        49.32                26.69
Sugar Division Office   Equipment         0                    18.65
               (Not considered by
               AO)
Chemical       Office   Equipment         0                    22.64
Division       (Not Considered by
               the AO)
               (B)                        0                    41.29
               (A)+(B)                                         67.98

7.    The CIT(A) rejected the contention of the assessee and confirmed the
addition.


8.    Aggrieved by the order of CIT(A), the assessee is in appeal before us
and filed the reconciliation statement as under:-


                         Distillery & Chemical Division

Additions to fixed assets during the previous year.

[To the extent of the difference that is relevant for the appeal]
     Addition on account of             As per book            As per Income Tax
                                          [In Rs.]                  [In Rs. ]
Plant & Machinery                               3,02,59,000              2,86,22,687
Furniture & Fixtures                               49,32,000               67,98,208


                                                                 Page 5 of 17
                                       6

                                               ITA NO 2220/Mum/2010
                                              Assessment year: - 2002-03
Office Equipment                                    18,66,000
Total                                             3,70,57,000                 3,54,20,95



Total Depreciation
With respect to               As per book     As per Income Tax Rate of depreciation
                                [In Rs.]           [In Rs.]
Plant & Machinery               1,69,19,000           2,72,67,807    [25% & 12.5%]
Furniture & Fixtures               2,45,000              9,39,152        [10% & 5%]
Office Equipment                   1,94,000



Total                           1,73,58,000          2,82,06,959


                                  Sugar Division
Additions to fixed assets during the previous year

[To the extent of the difference that is relevant for the appeal]

     Addition on account of            As per book         As per Income Tax [In Rs. ]
                                         [In Rs.]
Agriculture Machinery                             10,000           (General) 6,37,89,892
Plant & Machinery                           6,51,29,000               (Special) 13,48,883
Furniture & Fixtures                          18,02,000                       6,51,38,775
Office Equipment                              22,64,000                         40,65,104
Total                                       6,91,95,000                       6,92,03,879


Total Depreciation
With respect to               As per book      As per Income Tax            Rate of
                                [In Rs.]            [In Rs.]              depreciation




                                                                      Page 6 of 17
                                  7

                                          ITA NO 2220/Mum/2010
                                         Assessment year: - 2002-03
Agriculture Machinery           64,000 (General) 4,87,70,228    [25% & 12.5%]
Plant & Machinery          2,07,74,000      (Special) 6,74,441    [100% & 50%]
Furniture & Fixtures          3,90,000                 7,41,038     [10% & 5%]
Office Equipment              4,49,000


Total                      2,16,77,000            5,01,85,707




9.      The assessee submitted that the assessee has treated the item as
furniture & fixture of Rs. 49,32,000/- as per books while office equipment
of Rs. 18,66,000 in the distillery and chemical division while as per Income
Tax Act, the same is treated as furniture & fixtures of Rs. 67,98,208/-. The
assessee submitted that the asessee has claimed depreciation correctly in
the Income Tax Act as per the treatment and no prejudice is caused to the
Revenue and assessee has claimed less depreciation under the Income Tax
Act because the furniture & fixture carries the depreciation at the rate of
10% while plant and machinery carries the depreciation at the rate of 25%.
Similarly in the sugar division, the assessee has considered furniture &
fixture of Rs. 1802000/- and office equipment at Rs. 22,64,000/- under the
companies Act while as per Income Tax Act, the same is merged together
under the head furniture & fixtures of Rs. 40,65,104/- and hence correct
depreciation has been claimed. The assessee submitted that it has claimed
lower depreciation @ 10% on furniture & fixture under the Income Tax Act





                                                                Page 7 of 17
                                  8

                                            ITA NO 2220/Mum/2010
                                           Assessment year: - 2002-03
while depreciation of plant & machinery @ 25% under the Income Tax Act
and hence lower depreciation has been claimed and no prejudice is caused
to the Revenue.


10.   Ld. DR on the other hand relied upon the order of authorities below.


11.   We have considered the rival contention and carefully perused the
relevant material on record. We have observed that assessee has claimed
depreciation on furniture & fixture of Rs. 67,98,208/- in distillery &
chemical division and furniture & fixture of Rs. 40,65,104 in sugar division
and has claimed lower depreciation while merging the office equipment
into furniture & fixture an no prejudice is caused to the Revenue and hence
the claim of assessee is hereby allowed.




12.   Ground no. 2 is relating to stamp fee paid of Rs. 4,00,200/- for
agreement pertaining to co-generation project in respect of the agreement
entered into US grant/aid which was disallowed by the AO by considering
the same to be capital expenditure as the grant of Rs. 167.30 lac received
by the assessee has been considered as capital receipt.




                                                            Page 8 of 17
                                  9

                                          ITA NO 2220/Mum/2010
                                        Assessment year: - 2002-03
13.   The assessee carried the matter in appeal before CIT(A) and
submitted that the stamp fee has been incurred for getting a substantial
benefit for the business and should not be disallowed only because the
amount of benefit is on capital account. He relied upon the Judgment of
Hon'ble Supreme Court in the case of India Cements Ltd. Vs. Cit 60ITR 32
(SC), where it has been held that interest on loans borrowed for investing
is to be allowed. CIT(A) rejected the contention of the assessee and held
that AO has correctly capitalized on account of stamp fee for bringing the
asset into the company.


14.   Aggrieved by the order of CIT(A), the assessee is in appeal before us.


15.   Assessee submitted that the it has incurred the expenses for business
towards stamp fee for executing the agreement for subsidy for co-
generation project and the same should be allowed as it is a business
expense. The assessee relied upon the Judgment of Hon'ble Supreme Court
in the case of CIT Vs. General Insurance Corporation 286 ITR 232 (SC) and
the Judgment of Hon'ble Bombay High Court in the case of CIT Vs. Cinecita
(P.) Ltd. 137 ITR 652 (Bom.)




                                                             Page 9 of 17
                                    10

                                          ITA NO 2220/Mum/2010
                                         Assessment year: - 2002-03
16.   Ld. DR submitted that these are capital expenditure which is linked
towards the executing of the agreement for capital subsidy and hence the
same has rightly been disallowed.


17.   We have heard the rival submissions and carefully perused the
relevant material on record.     We are of the considered view that the
expenditure of Rs. 4,00,200/- was incurred by the assessee towards the
stamp fee is a capital expenditure which inextricably linked to the capital
subsidy of Rs. 167.30 lacs and thus we find no reasons to interfere with the
orders of authorities below and the same is hereby affirmed. We note that
the assessee has relied upon the decision of Hon'ble Supreme Court in the
case of CIT Vs. General Insurance Corporation (supra) which relates to
stamp duty paid for increase in authorized capital pursuant to the bonus
shares which was held to be the revenue expenditure because the bonus
shares does not entail any increase in capital which only relates to the
capitalization of existing profits and hence was held to be revenue
expenditure by the Hon'ble Supreme Court. Similarly the Judgment of
Hon'ble Bombay High Court in the case of CIT Vs. Cinecita (P.) Ltd. (supra)
relied upon by the assessee is also distinguishable because it relates to the
lease of 20 years entered into by the assessee, whereby the stamp duty,
professional /registration charges paid for preparation and getting
registered deed of lease was considered to be revenue expenditure.


                                                           Page 10 of 17
                                 11

                                         ITA NO 2220/Mum/2010
                                       Assessment year: - 2002-03
However, in the present case, the issue relates to the stamp fee paid for
execution of agreement of capital subsidy.


18.   Ground no. 3 is regarding confirming the charges of Rs. 19,37,524/-
u/s 41 in respect of sundry credits balance written off by the appellant
unilaterally.


19.   At the outset, the Ld. AR of the assessee submitted that the assessee
does not wish to press the grounds of appeal no. 3 and, therefore, the same
is hereby dismissed as not pressed.


20.   Ground no. 4 relates to the additional sugar cane price of Rs.
1,14,59,037/- which the assessee has claimed on the basis of purchase of
sugar cane.


21.   The assessee submitted that the assessee is in the business of sugar
in which it purchases sugar cane from farmers. Normally the sugar cane
prices are decided in three stages viz., 1st installment adhoc payment by
Central Advisory committee, second installment of case price is
recommended by State Government Committee and the third is decided by
Sugarcane Growers Association in the relevant area of activity .
Considering the same, the sugarcane price for season 2001-02 i.e. A.Y.


                                                          Page 11 of 17
                                 12

                                        ITA NO 2220/Mum/2010
                                       Assessment year: - 2002-03
2002-03 was decided at Rs. 8.25 per MT while the company had made
provision and paid in books of account @ 8.14 per MT. The final price of
the season 2001-02 was decided vide MOU with Cane Growers Association
and on the basis of the same, vide Internal Order dated 6/9/2014 the final
balance price works out as under:-


Season    Previous     A.Y.      Quantity        Rate per Amount (Rs.)
          Year                                   QTL
2001-02   20.09.01     2002-03 10,41,730,.658 11.00         1,14,59,037.24
          to 31.3.02


22.   In the return for assessment year 2004-05, the assessee had made
claim for the said additional cane price. However, the same was denied by
the AO stating that the assessee's contentioin is not acceptable since the
final cane price is determined as per settlement dated 6/9/04 which does
not fall in the previous year relevant to assessment year 2004-05. The
assessee submitted that it is following the mercantile system of accounting
and accordingly the claim should have been raised on accrual basis. The
sugarcane were consumed during the assessment year 2002-03 and
assessee is entitled to claim deduction of additional sugarcane of Rs.
1,14,59,037.24/-. Holding that assessee has not claimed these expenses in
return of income and no provisions has been made in books of account ,


                                                          Page 12 of 17
                                   13

                                          ITA NO 2220/Mum/2010
                                        Assessment year: - 2002-03
this claim made before the CIT(A) as additional ground of appeal as the AO
has also rejected the claim of the assessee for assessment year 2004-05.
The CIT (A) observed that assessee is claiming these expense on the basis
of agreement with the sugarcane grower association vide ...........order
dated 06.09.2004 and hence the claim has crystallized in the assessment
year 2005-06. The CIT(A) held that this claim cannot be allowed in the
assessment year 2002-03 and it will be examined on merits in the
assessment year 2004-05 or 2005-06 when it came up for hearing before
him.





23.    Aggrieved by the order of CIT(A), the assessee is in appeal before us.
Assessee submitted that this claim of Rs. 1,14,59,063/- got crystallized in
the assessment year 2005-06. Assessee submitted that in assessment year
2005-06, the CIT(A) presumed that it should be allowed in assessment
year 2006-07. Assessee submitted that it has filed a rectification
application u/s 154 before the CIT(A) for assessment year 2005-06 which
is still pending. It was also submitted that his claim got crystallized in
assessment year 2005-06 and hence should be allowed.


24.    On the other hand, Ld. DR submitted that it needs to be verified that
this be not allowed more than once as assessee is making claim in
assessment year 2002-03, 2004-05, 2005-06 and 2006-07.


                                                            Page 13 of 17
                                  14

                                         ITA NO 2220/Mum/2010
                                       Assessment year: - 2002-03


25.   We have considered the rival submissions. We hold that assessee is
following the mercantile system of accounting. Assessee is entitled for the
claim of expense on Revenue/trading account on crystallization of the law.
In the said amount in assessment year 2005-06 although it might pertain
to assessment year 2002-03. Hence assessee will be entitled for the said
claim for the assessment year 2005-06 subject to verification on merits by
authorities below about the bonafide and genuineness of the claim. The
authorities below are also directed to verify that the assessee's claim is
allowed not more than once. The assessee has claimed that this amount in
assessment year 2002-03, 2004-05, 2005-06 and 2006-07. Subject to
above verification additional claim should be allowed only in assessment
year 2005-06 subject to verification and checking by the authorities below
and hence the claim of assessee for impugned year is rejected.


26.   Ground no. 5 relates to claim of deduction u/s 80HHC of the Act.


27.   At the outset, we find that this ground of claim of deduction u/s
80HHC of the Act has been considered and decided by the Hon'ble Supreme
Court in the case of Ajanta Pharma Ltd. Vs. CIT [2010] 327 ITR 305 (SC).
Following observations of the Hon'ble Supreme Court is relevant.




                                                          Page 14 of 17
                                        15

                                                 ITA NO 2220/Mum/2010
                                               Assessment year: - 2002-03
      "10. One of the contentions raised on behalf of the Department was that if clause
      (iv) of Explanation to section 115JB is read in entirety including the last line
      thereof (which reads as "subject to the conditions specified in that section"), it
      becomes clear that the amount of profits eligible for deduction under section
      80HHC, computed under clause (a) or clause (b) or clause (c) of sub-section (3) or
      sub-section (3A), as the case may be, is subject to the conditions specified in that
      section. According to the Department, the assessee herein is trying to read the
      various provisions of section 80HHC in isolation whereas as per clause (iv)
      of Explanation to section 115JB, it is clear that book profit shall be reduced by the
      amount of profits eligible for deduction under section 80HHC as computed under
      clause (a) or clause (b) or clause (c) of sub-section (3) or sub-section (3A), as the
      case may be, of that section and subject to the conditions specified in that section,
      thereby meaning that the deduction allowable would be only to the extent of
      deduction computed in accordance with the provisions of section 80HHC. Thus,
      according to the Department, both "eligibility" as well as "deductibility" of the
      profit have got to be considered together for working out the deduction as
      mentioned in clause (iv) of Explanation to section 115JB. We find no merit in this
      argument. If the dichotomy between "eligibility" of profit and "deductibility" of
      profit is not kept in mind then section 115JB will cease to be a self-contained code.
      In section 115JB, as in section 115JA, it has been clearly stated that the relief will
      be computed under section 80HHC(3)/(3A), subject to the conditions under sub-
      sections (4) and (4A) of that section. The conditions are only that the relief should
      be certified by the Chartered Accountant. Such condition is not a qualifying
      condition but it is a compliance condition. Therefore, one cannot rely upon the last
      sentence in clause (iv) of Explanation to section 115JB [Subject to the conditions
      specified in sub-sections (4) and (4A) of that section] to obliterate the difference
      between "eligibility" and "deductibility" of profits as contended on behalf of the
      Department.
      11. For the above reasons, we set aside the impugned judgment of the High Court
      and restore the judgment of the Tribunal. Accordingly, the civil appeal of the
      assessee is allowed with no order as to costs."


28.   Respectfully following the Judgment of Hon'ble Supreme Court in the
case of Ajanta Pharma Ltd. Vs. CIT (supra), we decide this issue in favour of
the assessee and against the revenue.

                                                                       Page 15 of 17
                                      16

                                               ITA NO 2220/Mum/2010
                                             Assessment year: - 2002-03


29.    The assessee has also raised an Additional Ground, which reads as
under:-
       "The Ld. CIT (A) erred in taxing the amount of Rs. 19,37,534/- in respect of
       sundry credit balance written off by the appellant unilaterally, u/s. 28(iv) of
       the Act".


30.. At the time of hearing, the Ld. AR of the assessee submitted that the
assessee does not wish to press this Additional Ground and the same may
be dismissed. Accordingly, we dismiss the Additional Ground raised by the
assessee as the same is not pressed.



31.    In the result of appeal of the assessee is partly allowed.
Order pronounced in the open court on this 21st day of October 2015.



               Sd/-                                          Sd/-
          (Amit Shukla)                                 (Ramit Kochar)
      JUDICIAL MEMBER                              ACCOUNTANT MEMBER

 Mumbai;                 Dated :      21/10/2015
SKS Sr. P.S




                                                                   Page 16 of 17
                                        17

                                              ITA NO 2220/Mum/2010
                                             Assessment year: - 2002-03

Copy to:
      The Appellant
      The Respondent
      The concerned CIT(A)
      The concerned CIT
      The DR, "G" Bench, ITAT, Mumbai
                                                   By Order

                                             Assistant Registrar
                                             Income Tax Appellate Tribunal,
                                             Mumbai Benches, MUMBAI




                                                                 Page 17 of 17

 
 
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