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In absence of finding, penalty proceedings without jurisdiction: HC Full Bench
December, 16th 2008

Larger Bench of High Court deciding a bunch of Appeals vide a significant ruling has ruled   that power to impose penalty under Section 271 of the Act depends upon the satisfaction of the Income Tax Officer in the course of the proceedings under the Act. It cannot be exercised if he is not satisfied and has not recorded his satisfaction about the existence of the conditions specified in clauses (a), (b) and (c) before the proceedings are concluded. It is true that mere absence of the words I am satisfied may not be fatal but such a satisfaction must be spelt out from the order of the Assessing Authority as to the concealment of income or deliberately furnishing inaccurate particulars. In the absence of a clear finding as to the concealment of income or deliberately furnishing inaccurate particulars, the initiation of penalty proceedings will be without jurisdiction

In all these cases, the Income Tax Appellate Tribunal has either deleted or affirmed the deletion of penalty levied upon the assessee under Section 271(1)(c) of the Income Tax Act, 1961. The Tribunal has, while doing so, relied upon the decision of the Division Bench of High Court in CIT v. Ram Commercial Enterprises Ltd. and held that the authority initiating the penalty proceedings had not recorded its satisfaction regarding concealment of income or furnishing of inaccurate particulars thereof by the assessee. The Revenue assailed the correctness of the said orders in these appeals. According to the Revenue, penalty proceedings initiated by the competent authority should be deemed to be valid so long as the satisfaction of the authority was discernible from the order made by it. The fact that the authority had not used the words I am satisfied that the assessee has concealed his income or furnished inaccurate particulars thereof, would be of no consequence. The true test is whether a reading of the order demonstrates application of mind by the authority to the question of concealment and whether satisfaction about such concealment or furnishing of inaccurate particulars is discernible from the order. In the light of these submissions, the Division Bench admitted the appeals for determination of the following substantial question of law:

Whether satisfaction of the officer initiating the proceedings under Section 271 of the Income Tax Act can be said to have been recorded even in cases where satisfaction is not recorded in specific terms but is otherwise discernible from the order passed by the authority

Keeping in view the decision of High Court in CIT v. Ram Commercial Enterprises Ltd. and other cases on the subject, the Division Bench felt that it would be more appropriate if the question is authoritatively determined by a Full Bench of High Court and accordingly the matter was referred to the Full Bench.

IN THE HIGH COURT OF DELHI AT NEW DELHI

Reserved on : 14.11.2008
Date of decision: 27th November, 2008

ITA NOs. 211/2006, 791, 921, 1015, 1044, 1077, 1094, 1120, 1138, 1155, 1159, 1170 of 2005, 45, 79, 80, 105, 127, 167, 177, 193, 197, 213, 221, 251, 252, 306, 312, 315, 323, 326, 329, 331, 332, 339, 345, 417, 460, 490, 491, 492, 534, 548, 562, 565, 583, 590, 591, 600, 604, 635, 647, 657, 660, 664, 751, 752 and 766 of 2006

1. I.T.A. NO. 211/2006

Commissioner of Income Tax-V ....Appellant
versus
M/s Rampur Engineering Co. Ltd. .....Respondent

2 I.T.A. NO. 791/2005

Commissioner of Income Tax ....Appellant
versus
M/s Balka Services (P) Ltd. .....Respondent

3. I.T.A. NO. 921/2005

Commissioner of Income Tax ....Appellant
versus
M/s Canyam Constructions P. Ltd. .....Respondent

4. I.T.A. NO. 1015/2005

Commissioner of Income Tax ....Appellant
versus
M/s Bharat Cine Co. (P) Ltd. .....Respondent

5. I.T.A. NO. 1044/2005

Commissioner of Income Tax ....Appellant
versus
M/s Indus Valley Promoters Ltd. .....Respondent

6. I.T.A. NO. 1077/2005

Commissioner of Income Tax ....Appellant
versus
M/s Model Footwear (Pvt.) Ltd. .....Respondent

7. I.T.A. NO. 1094/2005

Commissioner of Income Tax ....Appellant
versus
M/s Gama Investments Pvt. Ltd. .....Respondent

8. I.T.A. NO. 1120/2005

Commissioner of Income Tax ....Appellant
versus
M/s Baid Credit and Portfolio Pvt. Ltd. .....Respondent

9. I.T.A. NO. 1138/2005

Commissioner of Income Tax ....Appellant
versus
M/s Basant Plasto Chemicals Pvt. Ltd. .....Respondent

10. I.T.A. NO. 1155/2005

Commissioner of Income Tax ....Appellant
versus
M/s Britika Exports (P) Ltd. .....Respondent

11. I.T.A. NO. 1159/2005

Commissioner of Income Tax ....Appellant
versus
M/s Baid Credit Portfolio (P) Ltd. .....Respondent

12. I.T.A. NO. 1170/2005

Commissioner of Income Tax ....Appellant
versus
Sh. Francis Wacziarg .....Respondent

13. I.T.A. NO. 45/2006

Commissioner of Income Tax ....Appellant
versus
M/s Abhishek Auto Industries Ltd. .....Respondent

14. I.T.A. NO. 79/2006

Commissioner of Income Tax ....Appellant
versus
M/s Bora Knitwear (P) Ltd. .....Respondent

15. I.T.A. NO. 80/2006

Commissioner of Income Tax ....Appellant
versus
M/s Singh Enterprises .....Respondent

16. I.T.A. NO. 105/2006

The Commissioner of Income Tax-V ....Appellant
versus
M/s Narain Jewels International Ltd. .....Respondent

17. I.T.A. NO. 127/2006

Commissioner of Income Tax ....Appellant
versus
M/s COSMO Films Ltd. .....Respondent

18. I.T.A. NO. 167/2006

Commissioner of Income Tax ....Appellant
versus
Shri Prakash Chandra Yadav .....Respondent

19. I.T.A. NO. 177/2006

The Commissioner of Income Tax-V ....Appellant
versus
M/s Narain Jewels International Ltd. .....Respondent

20. I.T.A. NO. 193/2006

Commissioner of Income Tax ....Appellant
versus
M/s Ajay Home Products Pvt. Ltd. .....Respondent

21. I.T.A. NO. 197/2006

Commissioner of Income Tax ....Appellant
versus
M/s Ajay Home Products Pvt. Ltd. .....Respondent

22. I.T.A. NO.213/2006

The Commissioner of Income Tax-III ....Appellant
versus
M/s Super Plastronices (P) Ltd. .....Respondent

23. I.T.A. NO. 221/2006

Commissioner of Income Tax ....Appellant
versus
M/s Dass Trading and Holding (P) Ltd. .....Respondent

24. I.T.A. NO. 251/2006

Commissioner of Income Tax-III ....Appellant
versus
M/s S.R. Ice and Cold Storage P. Ltd. .....Respondent

25. I.T.A. NO. 252/2006

Commissioner of Income Tax ....Appellant
versus
M/s Shree Joints International P. Ltd. .....Respondent

26. I.T.A. NO. 306/2006

Commissioner of Income Tax ....Appellant
versus
M/s Goenka Estates (Delhi) Pvt. Ltd. .....Respondent

27. I.T.A. NO. 312/2006

Commissioner of Income Tax-III ....Appellant
versus
M/s Sandeep Ceramics Ltd. ....Respondent

28. I.T.A. NO. 315/2006

Commissioner of Income Tax ....Appellant
versus
Francis Wacziarg .....Respondent

29. I.T.A. NO. 323/2006

Commissioner of Income Tax ....Appellant
versus
M/s Brahmputra Consortium Ltd. .....Respondent

30. I.T.A. NO. 326/2006

Commissioner of Income Tax ....Appellant
versus
Shri Sanjeev Kumar Gupta .....Respondent

31. I.T.A. NO. 329/2006

Commissioner of Income Tax ....Appellant
versus
M/s Dalmia Agencies (P) Ltd. .....Respondent

32. I.T.A. NO. 331/2006

Commissioner of Income Tax ....Appellant
versus
M/s Great Eastern Energy Corp. Ltd. .....Respondent

33. I.T.A. NO. 332/2006

Commissioner of Income Tax ....Appellant
versus
M/s D.G. Housing Projects Ltd. .....Respondent

34. I.T.A. NO. 339/2006

Commissioner of Income Tax ....Appellant
versus
Shri Sanjay Sharma .....Respondent

35. I.T.A. NO. 345/2006

Commissioner of Income Tax ....Appellant
versus
M/s Electrolux Kelvinator Limited .....Respondent

36. I.T.A. NO. 417/2006

Commissioner of Income Tax ....Appellant
versus
M/s Model Footwear (Pvt.) Ltd. .....Respondent

37. I.T.A. NO. 460/2006

Commissioner of Income Tax ....Appellant
versus
M/s Fracht Forwarding and Travels Pvt. Ltd. .....Respondent

38. I.T.A. NO. 490/2006

Commissioner of Income Tax ....Appellant
versus
Late Shri A.R. Chadha Th. L/H Sh. C. M. Chadha .....Respondent

39. I.T.A. NO. 491/2006

Commissioner of Income Tax ....Appellant
versus
Late Sh. A.R. Chadha Th. L/H Sh. C.M. Chadha .....Respondent

40. I.T.A. NO. 492/2006

Commissioner of Income Tax ....Appellant
versus
Late Sh. A.R. Chadha Th. L/H Sh. C.M. Chadha ....Respondent

41. I.T.A. NO. 534/2006

Commissioner of Income Tax ....Appellant
versus
M/s Deeksha Holding Ltd. .....Respondent

42. I.T.A. NO. 548/2006

Commissioner of Income Tax ....Appellant
versus
Ms. Madhushree Gupta .....Respondent

43. I.T.A. NO. 562/2006

Commissioner of Income Tax ....Appellant
versus
M/s Essan Remedies Ltd. .....Respondent

44. I.T.A. NO. 565/2006

Commissioner of Income Tax ....Appellant
versus
Mrs. Lata Chauhan .....Respondent

45. I.T.A. NO. 583/2006

Commissioner of Income Tax ....Appellant
versus
M/s Goodyear India Limited .....Respondent

46. I.T.A. NO. 590/2006

Commissioner of Income Tax ....Appellant
versus
M/s Goodyear India Limited .....Respondent

47. I.T.A. NO. 591/2006

Commissioner of Income Tax ....Appellant
versus
M/s Goodyear India Limited .....Respondent

48. I.T.A. NO. 600/2006

Commissioner of Income Tax ....Appellant
versus
M/s Eastern Holdings (P) Ltd. .....Respondent

49. I.T.A. NO. 604/2006

Commissioner of Income Tax ....Appellant
versus
M/s D.D. Gears Ltd. .....Respondent

50. I.T.A. NO. 635/2006

Commissioner of Income Tax ....Appellant
versus
M/s SRJ Securities (Now Adinath Capital Pvt. Ltd.) .....Respondent

51. I.T.A. NO. 647/2006

Commissioner of Income Tax ....Appellant
versus
M/s Maharani Paints (India) Pvt. Ltd. .....Respondent

52. I.T.A. NO. 657/2006

Commissioner of Income Tax ....Appellant
versus
M/s Ambuja Agro Industries Ltd. .....Respondent

53. I.T.A. NO. 660/2006

Commissioner of Income Tax ....Appellant
versus
Mr. S. Venkatnarayan .....Respondent

54. I.T.A. NO. 664/2006

Commissioner of Income Tax ....Appellant
versus
M/s Utkal Investment Ltd. .....Respondent

55. I.T.A. NO. 751/2006

The Commissioner of Income Tax-III ....Appellant
versus
M/s SIEL Industrial Estate Ltd. .....Respondent

56. I.T.A. NO. 752/2006

The Commissioner of Income Tax-III ....Appellant
versus
M/s Siel Industrial Estate Ltd. .....Respondent

57. I.T.A. NO. 766/2006

Commissioner of Income Tax ....Appellant
versus
M/s India Crafts .....Respondent

For the Appellant : Mr. R.D. Jolly, Mr. Sanjeev Sabharwal, Ms. Prem Lata Bansal, Mr. Prakash Chand Yadav, Mr. Sanjeev Rajpal, Mr. M.P. Gupta, Advs.

For Respondents : Mr. O.P. Bajpai, Adv. for respondent in ITA No. 460/2006 Mr. Gitanju Suraj, Mr. Jatin Zaveri, Advs. for respondent in ITA 345/2006 Mr. Ajay Vohra, Ms. Kavita Jha, Advs. for respondents in ITA Nos. 791/05, 583/2006, 590/2006, 591/2006 Mr. V.P. Gupta, Mr. Basant Kumar, Advs. for respondents in ITA Nos. 1094/2005, 79/2006, 490/2006, 491/2006, 492/2006, 604/2006 Mr. Prakash Kumar, Adv. for respondents in ITA Nos. 193/2006, 197/2006, 315/2006, 534/2006 Mr. Satyen Sethi, Mr. Johnson Bara, Advs. for respondents in ITA Nos. 127/2006, 323/2006

CORAM: HON'BLE THE CHIEF JUSTICE, HON'BLE MR. JUSTICE BADAR DURREZ AHMED and HON'BLE MR. JUSTICE RAJIV SHAKDHER

Date of judgment: 27th November, 2008

AIT Head Note: power to impose penalty under Section 271 of the Act depends upon the satisfaction of the Income Tax Officer in the course of the proceedings under the Act. It cannot be exercised if he is not satisfied and has not recorded his satisfaction about the existence of the conditions specified in clauses (a), (b) and (c) before the proceedings are concluded. It is true that mere absence of the words I am satisfied may not be fatal but such a satisfaction must be spelt out from the order of the Assessing Authority as to the concealment of income or deliberately furnishing inaccurate particulars. In the absence of a clear finding as to the concealment of income or deliberately furnishing inaccurate particulars, the initiation of penalty proceedings will be without jurisdiction. (Para 9)

J   U   D   G   M   E   N   T

AJIT PRAKASH SHAH, CHIEF JUSTICE

In all these cases, the Income Tax Appellate Tribunal has either deleted or affirmed the deletion of penalty levied upon the assessee under Section 271(1)(c) of the Income Tax Act, 1961. The Tribunal has, while doing so, relied upon the decision of the Division Bench of this Court in CIT v. Ram Commercial Enterprises Ltd. (2000) 246 ITR 568 (Delhi) and held that the authority initiating the penalty proceedings had not recorded its satisfaction regarding concealment of income or furnishing of inaccurate particulars thereof by the assessee. The Revenue has assailed the correctness of the said orders in these appeals. According to the Revenue, penalty proceedings initiated by the competent authority should be deemed to be valid so long as the satisfaction of the authority was discernible from the order made by it. The fact that the authority had not used the words I am satisfied that the assessee has concealed his income or furnished inaccurate particulars thereof, would be of no consequence. The true test is whether a reading of the order demonstrates application of mind by the authority to the question of concealment and whether satisfaction about such concealment or furnishing of inaccurate particulars is discernible from the order. In the light of these submissions, the Division Bench admitted the appeals for determination of the following substantial question of law:

Whether satisfaction of the officer initiating the proceedings under Section 271 of the Income Tax Act can be said to have been recorded even in cases where satisfaction is not recorded in specific terms but is otherwise discernible from the order passed by the authority

2. Keeping in view the decision of this Court in CIT v. Ram Commercial Enterprises Ltd. (supra) and other cases on the subject, the Division Bench felt that it would be more appropriate if the question is authoritatively determined by a Full Bench of this Court and accordingly the matter has been referred to the Full Bench.

3. We hasten to add that pending reference, sub-Section 1B has been inserted in Section 271 of the Income Tax Act by Finance Act, 2008. The said provision purports to create a fiction by which satisfaction of the assessing officer is deemed to have been recorded in cases where an addition or disallowance is made by the assessing officer and a direction for initiation of penalty proceedings is issued. The said provision is made effective retrospectively with effect from 1st April, 1989. In some of the cases forming part of this batch, the assessment orders were passed after 1st April, 1989. This reference is being answered only in respect of the cases where assessment orders were made prior to 1st April, 1989.

4. Learned counsel appearing for the Revenue strenuously contended that the question whether the authority was or was not satisfied about any concealment or furnishing of inaccurate particulars will depend upon the facts of each case and the order which the authority has made will have to be seen as a whole and so long as a proper reading of the order demonstrates application of mind by the authority and so long as satisfaction is discernible from the finding recorded by the authority initiating the proceeding, the same should suffice. Learned counsel contended that if on the facts available on record a clear case of concealment of income was made out then the Tribunal would not be justified in deleting the penalty. According to the learned counsel all such relevant facts available on record will have to be kept in view by the Tribunal in deciding the question as to whether the assessing officer has applied his mind to the question of concealment of income or furnishing of inaccurate particulars of any such income.

5. On the other hand, learned counsel appearing for the assessees submitted that the satisfaction as to the assessee having concealed the particulars of his income or furnished inaccurate particulars of such income is to be arrived at by the Assessing Officer during the course of any proceedings under the Act, which would mean the assessment proceedings, without which the very jurisdiction to initiate the penalty proceeding is not conferred on the assessing officer by reference to clause (c) of sub-section (1) of Section 271 of the Income Tax Act.

Learned counsel submitted that what actually prevailed with the Tribunal is the absence of any finding recorded by the assessing officer in the order of the assessment conferring jurisdiction for initiation of penalty proceedings. According to the learned counsel the decision of this Court in Ram Commercial Enterprises (supra) laid down the correct position of law.

6. Section 271(1)(c) of the Income Tax Act, 1961 provides:

271 (1) If the income Tax Officer, or the Appellate Assistant Commissioner in the course of any proceedings under this Act is satisfied that any person- (c) has concealed the particulars of his income or deliberately furnished inaccurate particulars of such income, he may direct that such person shall pay by way of penalty, -

......................................................

This is the provision as it stood at the relevant time. This provision fell for consideration of the Supreme Court in D.M. Manasvi v. Commissioner of Income Tax, Gujarat, II Ahmedabad (1972) 86 ITR 557 (SC) wherein the Supreme Court held that what is contemplated by sub-section (1) of Section 271 is that the Income Tax Officer or the Appellate Assistant Commissioner should have been satisfied in the course of proceedings under the Act regarding matters mentioned in the clauses of that sub-section. It is, however, not essential that notice to the person proceeded against should have been issued during the course of the assessment proceedings. Satisfaction in the very nature of things precedes the issue of notice and it would not be correct to equate the satisfaction of the Income Tax Officer or Appellate Assistant Commissioner with the actual issue of notice. The issue of notice is a consequence of the satisfaction of the Income Tax Officer or the Appellate Assistant Commissioner and it would be sufficient compliance with the provisions of the statute if the Income Tax Officer or the Appellate Assistant Commissioner is satisfied about the matters referred to in clauses (a) to (c) of sub-section (1) of Section 271 during the course of proceedings under the Income Tax Act even though notice to the person proceeded against in pursuance of that satisfaction is issued subsequently. The Court referred to the decision of the Constitution Bench in the case of Commissioner of Income-tax, Madras, and Anr. v. S.V. Angidi Chettiar (1962) 44 ITR 739 (SC) wherein Shah J. speaking for the Court while dealing with Section 28 of the Indian Income Tax Act, 1922, observed:

The power to impose penalty under Section 28 depends upon the satisfaction of the Income Tax officer in the course of proceedings under the Act; it cannot be exercised if he is not satisfied about the existence of conditions specified in clauses (a), (b) or (c) before the proceedings are concluded. The proceeding to levy penalty has, however, not to be commenced by the Income Tax Officer before the completion of the assessment proceedings by the Income Tax Officer. Satisfaction before conclusion of the proceeding under the Act, and not the issue of a notice or initiation of any step for imposing penalty is a condition for the exercise of the jurisdiction.

7. In Ram Commercial Enterprises Ltd. (supra) the argument of the Revenue was that on the facts available on record a clear case of concealment of income was made out and, therefore, the Tribunal was not justified in deleting the penalty. It was argued that all such relevant facts which were available on record were not kept in view by the Tribunal and, therefore, the findings arrived at by it are perverse and not binding on the High Court. The Division Bench following the law laid down in the case of D.M. Manasvi (supra) held:

11. .... The law is clear and explicit. Merely because this court while hearing this application may be inclined to form an opinion that the material available on record could have enabled the initiation of penalty proceedings that cannot be a substitute for the requisite finding which should have been recorded by the assessing authority in the order of assessment but has not been so recorded.

12. A bare reading of the provisions of Section 271 and the law laid down by the Supreme Court makes it clear that it is the assessing authority which has to form its own opinion and record its satisfaction before initiating the penalty proceedings. Merely because the penalty proceedings have been initiated, it cannot be assumed that such a satisfaction was arrived at in the absence of the same being spelt out by the order of the assessing authority. Even at the risk of repetition we would like to state that the assessment order does not record the satisfaction as warranted by Section 271 for initiating the penalty proceedings....

8. The view taken in Ram Commercial Enterprises (supra) has been followed in Diwan Enterprises v. Commissioner of Income Tax (2000) 246 ITR 571 (Delhi) and Commissioner of Income Tax v. J.K. Synthetics Ltd. (1996) 219 ITR 267 (Delhi). Same is the view taken by the Bombay High Court in Commissioner of Income-tax v. Dajibhai Kanjibhai (1991) 189 ITR 41 (Bom).

9. In our opinion, the legal position is well settled in view of the Supreme Court decisions in Commissioner of Income Tax, Madras. and Anr. v. S.V. Angidi Chettiar (supra) and D.M. Manasvi v. Commissioner of Income Tax, Gujarat, II Ahmedabad (supra), that power to impose penalty under Section 271 of the Act depends upon the satisfaction of the Income Tax Officer in the course of the proceedings under the Act. It cannot be exercised if he is not satisfied and has not recorded his satisfaction about the existence of the conditions specified in clauses (a), (b) and (c) before the proceedings are concluded. It is true that mere absence of the words I am satisfied may not be fatal but such a satisfaction must be spelt out from the order of the Assessing Authority as to the concealment of income or deliberately furnishing inaccurate particulars. In the absence of a clear finding as to the concealment of income or deliberately furnishing inaccurate particulars, the initiation of penalty proceedings will be without jurisdiction. In our opinion, the law is correctly laid down in Ram Commercial Enterprises (supra) and we are in respectful agreement with the same. The reference is answered accordingly.

10. Let the individual cases be listed before the appropriate Bench on 4th December, 2008 for hearing and disposal.

 
 
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