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 ITO vs. Vikram A. Pradhan (ITAT Mumbai)

Microsoft Corporation India Pvt. Ltd., F-40, NDSE, Part I, New Delhi. Vs. Addl. CIT, Range-6, CR Building, New Delhi.
December, 19th 2014
         IN THE INCOME TAX APPELLATE TRIBUNAL
              DELHI BENCHES : I : NEW DELHI

BEFORE SHRI R.S. SYAL, AM AND SHRI GEORGE GEORGE K, JM

                       ITA No.5855/Del/2010
                     Assessment Year : 2006-07


Microsoft Corporation India       Vs.   Addl. CIT,
Pvt. Ltd.,                              Range-6,
F-40, NDSE, Part I,                     CR Building,
New Delhi.                              New Delhi.

PAN : AAACM5586C

  (Appellant)                              (Respondent)


           Assessee by        :    Shri Percy Pardiwala, Sr. Advocate
                                   & Shri Vishal Rai
           Department by      :    Shri Peeyush Jain, CIT, DR &
                                   Shri Vivek Kumar, Sr. DR


                                  ORDER

PER R.S. SYAL, AM:

     This appeal by the assessee arises out of the final order

passed by the Assessing Officer (AO) u/s 143(3) read with section

144C of the Income-tax Act, 1961 (hereinafter also called `the

Act') on 25.10.2010 in relation to the assessment year 2006-07.
                                                         ITA No.5855/Del/2010


2.     Ground Nos. 1 and 2 are general which do not require any

adjudication.


3.     Ground No. 3 is against restricting the rate of depreciation

on ITG Networking Equipments at 25% as against 60% claimed by

the assessee.     Briefly stated, the facts of this ground are that the

assessee claimed depreciation @ 60% on ITG Networking

Equipments under the block of Computers. The AO, following his

order for the AY 2002-03, restricted the rate of depreciation to

25%.


4.     After considering the rival submissions and perusing the

relevant material on record, it is noticed from the assessment

order itself that the AO restricted the claim of depreciation on ITG

Networking Equipments by relying on the view taken by him for

the AY 2002-03.         The said assessment year came up for

consideration before the Tribunal in ITA No.4173/Del/2010. Vide

its order dated 19.11.2010, a copy of which is available on record,

the    Tribunal   accepted   the   applicability   of   higher   rate     of

depreciation by relying on the Special Bench order passed in the

case of DCIT vs. Data Craft India Ltd. (2010) 133 TTJ (Mumbai)(SB)


                                   2
                                                      ITA No.5855/Del/2010


377. In the absence of any distinguishing feature having been

brought to our notice by the ld. DR about the facts of the instant

year and the preceding year, we, respectfully following the

precedent, allow this ground of appeal.


5.     The next ground is against the disallowance of depreciation

on company owned vehicles amounting to `1,23,84,597/-.              The

facts apropos this ground are that the assessee claimed

depreciation for the said amount on vehicles which were owned

by it but used by its employees. The AO observed in finalizing the

assessment for the assessment year 2005-06, which has been

followed for the instant year, that the employees were deciding

about the car which they wanted to purchase and, in case of

purchase of higher category than the sanctioned amount, the

additional amount was contributed by them. He further observed

that    the   employees   were    responsible   for   running       and

maintenance of vehicles and any damage in excess of normal

wear and tear, was the sole responsibility of the employees. The

fact that the assessee purchased the cars and paid road tax

liability on such cars, did not weigh with the AO, who came to



                                 3
                                                    ITA No.5855/Del/2010


hold that depreciation was not allowable because of the personal

use of vehicles.


6.   After considering the rival submissions and perusing the

relevant material on record, we find it as an undisputed fact that

the company provided vehicles to its employees for their use for

which the purchase price was paid by the company,          unless it

exceeded the benchmark fixed by it. The major reason given by

the AO for disallowing depreciation is the personal use of vehicles

by the employees of the company.         The Delhi Bench of the

Tribunal in DCIT vs. Haryana Oxygen Ltd. (2001) 76 ITD 32 (Del)

has held that use of car by directors-employees of a company

cannot be characterized as user for non-business purpose and,

hence, no part of car expenses incurred on such cars can be

disallowed. The Hon'ble Gujarat High Court in Sayaji Iron and

Engineering Company vs. CIT (2002) 253 ITR 749 (Guj) has held

that once the directors of the assessee company were entitled to

use the vehicles of the company for the personal use as per the

terms and conditions of their appointment, it cannot be said that

the assessee incurred expenditure for the personal use of cars by

the directors. The Hon'ble High Court further held that such user
                                 4
                                                   ITA No.5855/Del/2010


of vehicles by the employees of the company cannot even be

considered as `non-business user".       There are innumerable

judgments on this point holding that there can be no disallowance

of depreciation or other expenses on maintenance of the vehicles

used by the directors/employees by treating it as personal user or

non-business user of the company. We fail to see any rationale in

treating the amount of depreciation on cars as for personal use,

when admittedly these have been provided to employees. A

company is a separate legal entity distinct from its directors or

employees. As such, there can be no occasion to treat the use of

vehicles by the directors/employees as a personal use by the

company. We, therefore, order for the deletion of the addition of

depreciation on such vehicles.


7.   Ground No. 5 is against the disallowance of     `78,25,822/-

towards running and maintenance expenses of the vehicles used

by the employees of the assessee company. The AO, following

the direction of the Dispute Resolution Panel (DRP), held that 50%

of running and maintenance expenses of the vehicles were to be

disallowed for non-business purpose.



                                 5
                                                            ITA No.5855/Del/2010


8.     After considering the rival submissions and perusing the

relevant material on record, we find that this issue is squarely

covered by the above referred judgments of the Hon'ble Gujarat

High Court and the Tribunal order passed by the Delhi Bench.

The same analogy which applies for not making any disallowance

on account of depreciation for personal or non-business use,

equally applies for not warranting any disallowance on account of

running and maintenance expenses of the vehicles used by the

employees of the company. We, therefore, order for the deletion

of the addition.





9.   Ground No. 6 is against the disallowance of `Prior period

expenses'     amounting to `78,63,993/-. The assessee raised an

additional   ground   before   the       DRP   requesting    for    allowing

deduction of expenses incurred for the AY 2006-07, which were

debited to the Profit & Loss (Appropriation) Account for the AY

2007-08, without making any claim for deduction of such

expenses in the computation of income for the said assessment

year. The DRP did not deal with this ground. That is how, the

assessee is in appeal before us on this aspect of the matter.



                                     6
                                                      ITA No.5855/Del/2010


10. We have considered the rival submissions and perused the

relevant material on record. It is pertinent to note that we are

dealing with the assessment year 2006-07 with the financial year

ending on 31.3.2006. In its Annual accounts for the year ending

31.3.2007,   the   assessee    debited   `Prior   period   expenses'

amounting to `83,62,295/-. These expenses were voluntarily not

claimed as deduction in the computation of income for the AY

2007-08. A claim was lodged before the DRP during the course of

the proceedings for the A.Y. 2006-07 that deduction be allowed

for a sum of `78,64,013/- as these much expenses out of the total

of `83.62 lakh, discharged during the succeeding year related to

the year under consideration. It is axiomatic that the `Prior period

expenses' appearing in the accounts for the AY 2007-08 would

mean that the expenses were incurred for the earlier years

including assessment year 2006-07. If there are some expenses

incurred for the business, which are otherwise deductible, then

deduction must follow. It cannot be a case that such expenses

would not qualify for deduction either in the year of incurring or in

the year to which they relate. Adverting to the facts of the instant

case, it is seen that the assessee incurred some expenses for the

                                  7
                                                     ITA No.5855/Del/2010


period relevant to the A.Y. 2006-07 during the period relevant to

the A.Y. 2007-08 without claiming deduction in the computation

of income of any of the years. Such expenses deserve to be

allowed as deduction in the computation of income, to which they

pertain. As the `Prior period expenses' in the accounts for the A.Y.

2007-08 indicate that they pertain to the A.Y. 2006-07, these

should be rightly allowed as deduction in such earlier year. It is

not a case that the assessee is seeking deduction for `Prior period

expenses' appearing in its accounts for the AY 2006-07.            It is

simply contending for deduction of expenses relating to the AY

2006-07 discharged in the period relevant to the AY 2007-08.

There can be no reason to deny deduction for such expenses

genuinely incurred for the purpose of business, if these are

otherwise deductible as per law. Since the AO did not have an

occasion to consider the otherwise deductibility of such expenses,

we are of the considered opinion that the ends of justice would

meet adequately if the impugned order on this issue is set aside

and the matter is restored to the file of AO. We order accordingly

and direct him to scrutinize the details of such `prior period

expenses' booked in the accounts for AY 2007-08 for ascertaining

                                 8
                                                      ITA No.5855/Del/2010


if these were incurred for the AY 2006-07 and then to that extent

allow deduction, if these are otherwise deductible.


11. The only other ground which survives for our consideration is

against the addition of `28,55,40,322/- made on account of

transfer pricing adjustment. Briefly stated, the facts of the case

are that the assessee reported four international transactions,

viz., `Provision of marketing support services' with value of

`324,73,13,183/-; Provision for regional guest employee services;

Provision of Microsoft consulting services; and Assignment of

personnel.   The Transfer Pricing Officer (TPO) got satisfied with

the arm's length price (ALP) of all the international transactions

except the first one, namely, `Provision of marketing support

services'.   The assessee adopted Transactional net margin

method (TNMM) as the most appropriate method to benchmark

this international transaction. Profit level indicator (PLI) was

adopted as Operating profit/Total cost (OP/TC).       The assessee

computed its percentage of operating profit margin at 12.39% in

comparison with that of nine comparables, on the basis of

multiple year data, at 7.32%. That is how, the assessee

demonstrated that this international transaction was at ALP. The
                                 9
                                                     ITA No.5855/Del/2010


TPO required the assessee to furnish benchmark analysis of these

comparable companies by using the current year data alone. In

doing so, the assessee reduced the comparables to seven. The

TPO rejected three companies given by the assessee and added

five new companies in the final list of comparables. In doing this

exercise of rejecting some of the companies chosen by the

assessee and including new companies, the TPO observed that

the assessee was not only engaged in the dissemination of

information and performing low-end non-complex functions, but

also creating significant intangibles. He reached this conclusion

despite the assessee's submission that it was simply creating

awareness of the Microsoft products amongst the existing and

potential users by holding seminars, conferences, advertisement

in public media and promotional campaigns which was nothing

more than marketing support services. The assessee's contention

that it was performing such activities on cost plus basis, without

creating any intangibles for its AEs, did not persuade the TPO in

holding that the assessee was creating substantial marketing

intangibles in India for its AEs. He determined OP/TC of the finally

selected nine companies at 22.18%.       That is how, the transfer

                                 10
                                                     ITA No.5855/Del/2010


pricing adjustment amounting to `28.55 crore was proposed,

which was made by the AO. The assessee is aggrieved against

such addition.


12. We have heard the rival submissions and perused the

relevant material on record. There is no dispute on the fact that

the assessee benchmarked the international transaction of

`Provision of marketing support services' by selecting TNMM,

which has also been accepted by the TPO as the most appropriate

method.   The change of benchmarking done by the TPO of the

comparables on the basis of single year data instead of multiple

year data, has also not been assailed by the assessee. In fact, no

other aspect of the TP adjustment has been challenged except

the determination of PLI of the comparables.        Here again, the

assessee has confined itself to challenging the inclusion of five

new companies by the TPO in the final list of comparables. We

are,   therefore,   restricting   ourselves    in   examining       the

comparability or otherwise of the five new companies introduced

by the TPO in the final list of comparables.




                                  11
                                                     ITA No.5855/Del/2010


13. Before embarking upon making an analysis of comparability,

it is sine qua non to first ascertain the correct nature of the

assessee's activity under the segment of `Provision of marketing

support services.' The assessee's Transfer pricing study report

indicates that the assessee, a wholly owned subsidiary of

Microsoft   Corporation,   provided   marketing   support    services

mainly to Microsoft Corporation Pte Ltd., Singapore and a small

portion of revenue arose from services rendered to Microsoft

Corpn., UK.   The assessee was compensated for such services

with actual costs incurred with a mark-up of 15% for services

rendered to Microsoft Corporation Pte Ltd., Singapore and 10% for

services rendered to Microsoft Corpn., UK.        All the operating

expenses, depreciation, realized foreign exchange gain/loss and

bank charges were taken into account for calculating the mark-

up. The TPO has reproduced relevant clauses of the assessee's

Agreement with Microsoft Corporation Pte Ltd., Singapore on page

4 onwards of his order.      This Agreement stipulates that the

assessee shall provide Product support services and consulting

services for the Microsoft products in the defined territory. Clause

3 of the Agreement provides that the assessee `shall have a non-

                                 12
                                                         ITA No.5855/Del/2010


exclusive right to market Microsoft Products in the Territory.'          Its

duties have been set out in clause 3.2 by providing that the

assessee shall use its best efforts to further the interest of MO

and maximize the markets for Micorsoft products in the territory.

It has also been provided that the assessee in soliciting orders

shall only be authorized to inform customers of price, payment

delivery and other terms offered by MO in accordance with

information received from MO or its affiliates. It further provides

that the assessee `shall not enter into any agreements with

customers    regarding   Microsoft    products,    but   shall    instead

promptly submit written customer orders to MO or its affiliates as

appropriate, for its acceptance or rejection.'           The nature of

services provided by the assessee to Microsoft Corporation, USA

is also that of marketing research and development. Thus, it can

be seen that the assessee is basically engaged in creating

awareness of Microsoft products amongst existing and potential

users   of   Microsoft   products     in   India   through     seminars,

conferences, advertisement in public media and promotional

campaigns. All the expenses incurred by the assessee on such

sales promotion activities have been completely reimbursed to

                                 13
                                                      ITA No.5855/Del/2010


the assessee with a mark-up of 15% by Singapore AE.                Even

though some marketing intangibles get created by the assessee's

spending on advertisement and marketing expenses, such

intangibles belong to its AEs because the assessee is not

indulging in any sale or purchase activities of Microsoft products

at its own.


14.   The TPO has referred to certain clippings, mostly relating to

the period of October/November, 2008 to bring home his point

that the assessee is providing high-end marketing services after

identifying the customers and its job is not simply to create

market awareness by performing a low-end non-complex function.

This, in the opinion of the TPO, is done by the launching of the

products with big advertisement campaigns, customer interface

and provision for training and back-up for use of products and

softwares. In this regard, it is firstly relevant to note that we are

dealing with the AY 2006-07 and the relevant financial year ends

on 31.3.2006. All the clippings referred to by the TPO relate to

subsequent years.    Be that as it may, it can be seen that the

inference drawn by the TPO that the assessee is not only engaged

in the dissemination of information, but also providing high-end
                                 14
                                                      ITA No.5855/Del/2010


marketing services leading to creation of marketing intangible for

its AE, is not correct. It can be seen from the clipping dated 24th

November, on page 19 of the TPO's order that Microsoft

Corporation India Pte Ltd., announced the availability of the Get

Genuine Solutions (GGS) for Windows, Vista through which

customers were able to legalise their counterfeit or unlicensed

Windows XP Professional PCs under GGS by simply `place(ing) an

order with their reseller to legalise their counterfeit software.'

From the above, it is clear that the assessee is nowhere engaged

in the actual selling of the products to the customers directly. It is

simply providing marketing support services by creating customer

awareness for the Microsoft products and also in certain cases

providing trainings and back-ups for the use of such products and

softwares. With this background of the nature of the assessee's

activity under this segment, let us analyse as to whether the five

companies chosen by the TPO are, in fact, comparables.


i. Engineers (India) Ltd. :


15.1.   The assessee contended before the TPO that this company

was providing engineering and related technical services for


                                  15
                                                           ITA No.5855/Del/2010


petroleum refineries and other industrial projects and, hence,

could not be compared with the assessee.             Not convinced, the

TPO included this company in the list of comparables by noticing

that the assessee itself used this company as comparable for the

assessment years 2003-04 and 2004-05. In view of the fact that

the assessee included this company in the list of comparables for

the earlier years, the TPO held that it must be so included in the

final list of comparables for the instant year as well.


15.2.   We do not find any force in the view canvassed by the TPO

for including this company in the list of comparables simply on

the strength of the assessee treating it as comparable for the AYs

2003-04 and 2004-05. It goes without saying that there can be

no estoppel against the correct position of comparability. Simply

because the assessee chose an incomparable company as

comparable for an earlier year, cannot bind it for all the years to

come.    What   is   required   to        be   examined   is   the    actual

comparability for the year in question rather than what was done

in the past.    If the assessee, having included the name of a

company in its comparables for the earlier years or even for the

current year, contends before the TPO or DRP etc., that this
                                     16
                                                       ITA No.5855/Del/2010


company is not, in fact, comparable, then it is for the authorities

to first decide the comparability on merits and then proceed for

its inclusion or exclusion in/from the list of comparables. A mere

claim made by the assessee for considering a company as

comparable, does not ipso facto lead to its final inclusion or

exclusion.    It is only when the TPO examines the assessee's

contention that he can reach a positive conclusion about the

comparability of such a company. Same position equally applies

to the TPO as well.    Simply because a particular company was

wrongly   excluded    by   him   in    determining   the   ALP    of   an

international transaction for an earlier year, cannot debar him

from including it in the list of comparables in the succeeding year,

if it is actually comparable.    The essence of the matter is to

examine the comparability and not the fact as to whether it was

included or excluded in the past or in the future.





15.3.   It can be seen from the TPO's order that he insisted on the

inclusion of this company on the sole reason of the assessee

treating it as comparable for the two earlier years. Such a view

cannot be countenanced without examining the correct nature

and the functional profile of this company.
                                  17
                                                        ITA No.5855/Del/2010


15.4.       It can be seen that Engineers (India) Ltd., is a company

providing     engineering   and   related   technical    services       for

petroleum refineries and other industrial projects. This company

has two business segments, namely, Consultancy & Engineering

projects and Lumpsum Turnkey projects.        These services are in

the nature of engineering services, which, by no standard, can be

compared with the marketing support services provided by the

assessee to its AEs. The Hon'ble jurisdictional High Court in CIT

vs. Verizon India (P) Ltd. (2014) 360 ITR 342 (Del) has held that

marketing services cannot be compared with the engineering

services. In that case, the assessee provided marketing services

and the authorities below considered some companies, providing

engineering services, as comparable.        The Hon'ble High Court

approved the view taken by the Tribunal in holding that

marketing services provided by that assessee were entirely

different from the set of services in the nature of engineering

services rendered by the comparables. As admittedly, Engineers

(India) Ltd., is engaged in providing engineering services, the

same cannot be considered as comparable with the assessee,



                                  18
                                                      ITA No.5855/Del/2010


who is engaged in providing marketing support services.             This

company is, therefore, directed to be excluded from comparables.


(ii)    RITES Ltd. :


16.1.      This company was considered by the TPO as comparable

on the same reasons, being, the assessee's inclusion of this

company in the list of comparables for the AYs 2002-03 and 2003-

04.


16.2.      We find that this company is primarily a consultancy

organization rendering consultancy services in all facets of

transportation.        Its major areas of operations are consultancy

services; Export of Rolling Stock, Equipments and Spares; and

leasing of Railway Rolling Stock and Equipments. It can be seen

that the functional profile of this company is nowhere near the

assessee, which is simply providing marketing support services by

largely creating customer awareness for the Microsoft products in

India. This company is, therefore, directed to be excluded.




                                    19
                                                         ITA No.5855/Del/2010


(iii) TCE Consulting Engineers Ltd.:


17.1.    This company was considered by the TPO as comparable

on the same reasons, being,        the assessee's inclusion of this

company in the list of comparables for the AYs 2002-03 and 2003-

04.


17.2.    It is noticed that this company is engaged in the provision

of    engineering   services,   such   as,   operation     and     design

engineering, upgradation & renovation services, surveys & field

investigation services. This company is operating only in one

segment, namely, engineering consultancy services.               As such,

there can be no comparison of this company with the assessee

company. This company is also directed to be expelled from the

list of comparables.


(iv) WAPCOS:


18.1.    This company was considered by the TPO as comparable

on the same reasons, being, the assessee's inclusion of this

company in the list of comparables for the AYs 2002-03 and 2003-

04.



                                  20
                                                      ITA No.5855/Del/2010


18.2.      We find that this company operates in two segments,

namely, Consultancy & engineering projects and Lumpsum

turnkey projects.      This company provides consultancy services,

such as, pre-feasibility report of hydroelectric projects, field

investigation drilling of tube wells, etc.        From the above

description of the nature of activities performed by this company,

it can be seen that the same is engaged in providing engineering

and consultancy services, which can be of no match to the

assessee's marketing support services.        This company is also

directed to be excluded from the list of comparables.


v)      Vinita Labs Ltd.:


19.1.      The TPO included this company in the list of comparables

by noticing that it has been so used as comparable to the

assessee by the TPO since the AY 2002-03. He further supported

his finding by noticing that this company was providing similar

services as provided by the assessee.


19.2.     We do not find any force in the functional comparability of

this company with the assessee. It can be seen from the Annual

report of this company, a copy of which is available at page 155

                                   21
                                                        ITA No.5855/Del/2010


of the third paper book, that the spectrum of the services

rendered by this company covers analytical food and drugs;

clinical reference lab services to address the specialties and

central lab services for clinical trials; clinical trials phase-I-IV and

BA/BE studies; pre-clinical safety assessments; and environmental

assessments.     On a cursory look at the nature of services

provided by this company, it transpires that the same is

functionally dissimilar from that of the assessee. How a company

conducting clinical trials on foods and drugs can be considered as

comparable with the assessee undertaking marketing support

services, is anybody's guess. This company being in the nature of

business totally alien to that of the assessee, cannot be

considered as a comparable. We, therefore, direct the exclusion

of this company from the list of comparables.


20.       No other issue of the addition on account of the TP

adjustment was pressed by the ld. AR.


21.   In view of the above discussion, we set aside the impugned

order on this score and send the matter back to the file of TPO/AO

with a direction to re-compute arm's length price of the


                                   22
                                                      ITA No.5855/Del/2010


international transaction of `Provision of market support services'

afresh by excluding these five companies from the list of

comparables. All other aspects of the computation of ALP done by

the TPO earlier, are final. Needless to say, the assessee will be

allowed a reasonable opportunity of being heard in such fresh

exercise.


22. In the result, the appeal is partly allowed.


          The order pronounced in the open court on 18.12.2014.



              Sd/-                                     Sd/-

 [GEORGE GEORGE K.]                               [R.S. SYAL]
   JUDICIAL MEMBER                            ACCOUNTANT MEMBER


Dated, 18th December, 2014.

dk

Copy forwarded to:

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

                                               AR, ITAT, NEW DELHI.


                                   23

 
 
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