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From the Courts »
  Vatsala Shenoy vs. JCIT (Supreme Court)
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 ITO vs. Vikram A. Pradhan (ITAT Mumbai)

Ion Exchange (I) Ltd., In House, 4th Floor, Dr. E.Moses Rd., Mahalaxmi, Mumbai 400011 Vs. The Addl. CIT 6 (1) Aaykar Bhavan, MK Road, Mumbai 400 020
February, 25th 2014
                     , 
          IN THE INCOME TAX APPELLATE TRIBUNAL
                MUMBAI BENCHES `K' MUMBAI
               [^ .. , Û  /
              Û]    ãá,                ¢ 
     BEFORE SHRI I.P. BANSAL, JUDICIAL MEMBER    /AND

          SHRI N.K.BILLAIYA, ACCOUNTANT MEMBER
              . / ITA No. 5109/MUM/2013
                [ [ /Assessment Year 2008-09

Ion Exchange (I) Ltd.,      / The Addl. CIT 6 (1)
In House, 4th Floor,            Aaykar Bhavan, MK Road,
                            Vs.
Dr. E.Moses Rd., Mahalaxmi,     Mumbai 400 020
Mumbai 400011
    . /   . / PAN/GIR No. : AAACI 1726L

    ( /Appellant)           ..       (× / Respondent)
               . / ITA No. 5334/MUM/2012
                [ [ /Assessment Year 2008-09

The Addl. CIT 6(1),        / Ion Exchange (I) Ltd.,
Aaykar Bhavan, MK Road,        In House, 4th Floor,
                           Vs.
Mumbai 400 020.                Dr. E.Moses Rd., Mahalaxmi,
                               Mumbai 400011

    . /   . / PAN/GIR No. : AAACW 2067L

    ( /Appellant)           ..       (× / Respondent)


 Assessee by :       Shri PRV Raghavan
 Respondent by :     Shri Abhinay Kumbhar
           / Date of Hearing        : 10/02/2014
          /Date of Pronouncement : 10/02/2014
                                           2          . / ITA No. 5109&5334/MUM/2013
                                                             [ [ /Assessment Year 2008-09




                                    / O R D E R

PER I.P.BANSAL,J.M:

     These     cross appeals       are directed against order dated 21/05/2013
passed by Ld. CIT(A)-15, Mumbai for assessment year 2008-09.                Grounds of
appeal read as under:

     Grounds of Assessee's Appeal:

      1. Addition on a/c of imputed interest on Loans / advances to Foreign
     AEs :-
     The Hon'ble Commissioner of Income-tax (Appeals) 15, Mumbal (The learned
     CITA) has erred in law and on facts, vide paragraph 4.5 at page nos.9 to 11 of
     his Appellate Order, in directing the AO to consider the interest on Foreign AEs ©
     LIBOR plus 250 basis point and/or LIBOR p/us 150 basis points on the
     advances.

     2. Disallowance u/s 14A:-

     a. The learned CITA has erred in law and on facts, vide paragraph 5 at page
     no.11 to 16 of his Appellate Order, in upholding AC's calculation of an amount of
     Rs.408,412/- towards expenditure incurred u/s 14A for a dividend income of
     Rs.900,459/-
     b. Without prejudice, it is submitted, that at the most the AO, in order to justify a
     very small and negligible amount of time, effort and expenditure is required to
     earn dividend income, should have disallowed O.5% of such exempt income.
     c. Without prejudice, it is submitted, that at the most the AO, should have
     followed the precedence of AY 2007--2008 in your Appellant's own case.
     d. In doing so, the CITA has overlooked the fact that the AC had already
     disallowed certain expenses of interest on the so-called investments in shares out
     of borrowed funds and, thus, this disallowance is a double jeopardy.

     3. Disallowance of Interest free advances to subsidiary companies /
     Disallowance of Interest expenditure on Investment for Controlling
     Interest :-
     a. The learned CITA has erred in law and on facts in upholding, vide paragraph 6
     at page 17 to 21 of his Order, the disallowance of Rs.238,580/- incurred on
     interest on funds borrowed by it, which do not appear to have been deployed for
     the purposes of their business but utilised for lending to your appellants group
     companies and subsidiaries.
      b. The learned CIT(A) has erred in law and on facts in overlooking your
     Appellants contention that     in para 7 of the Assessment Order, the AO has
     extensively discussed certain court decisions without discussing the same at the
     time of assessment proceedings. The learned CITA has not disposed off this
                                     3          . / ITA No. 5109&5334/MUM/2013
                                                      [ [ /Assessment Year 2008-09



ground even though the same is appearing in his Appellate Order at para 6.3.11.
at page 20.

c. The learned CITA has erred in law and on facts in upholding, vide paragraphs
7 at page no.21 to 23 of his Order, the disallowance of Rs. 19,63,590/- made by
the ITO on interest expenditure being capital in nature attributable to investment
in subsidiaries for controlling interest.

d. The learned CIT(A) has erred in law and on facts in overlooking your
Appellants contention that in para 8 of the Assessment Order, the AO has
extensively discussed certain court decisions without discussing the same at the
time of assessment proceedings. The learned CITA has not disposed off this
ground even though the same is appearing in his Appellate Order at para 7.3.ii.
at page 23.




e. The learned CIT(A) has erred in law and on facts in not appreciating the
evidence of the Order of the Hon'ble Bombay High Court dated April 04, 2000,
along with the Scheme of Amalgamation of Hydranautics Membranes India
Limited and Ion Exchange Finance Limited with your Appellants.

f. The learned CIT(A) ought to have appreciated the fact in the absence of
establishing any clear nexus that the borrowed funds were used for making the
said advance, it cannot be said that the borrowed funds were used for making
the said advance.

4. Addition on account of interest on borrowed capital towards Capital Work in
Progress:

a. The learned CITA has erred in law and on facts, vide paragraph 9 at page
nos.25 to 27 of his Appellate Order, in upholding the disallowance of Rs.39,024/-
towards interest paid on borrowed fund towards capital work in progress.

b. The learned CITA has erred in law and on facts, vide paragraph 9.4.11 at page
nos.27 of his Appellate Order, in holding that Hon'ble Supreme Court's decision in
Tuticorin Alkali chemicals & Fertilizers Ltd. Vs CIT (1997) 227 ITR 172 (SC) is not
applicable in your Appellants case.
5. General - The learned CITA has erred in law and on facts, vide paragraph 12
at page no.30 of his Appellate Order, in holding that the mistake in date of Notice
of Demand could be clerical / typographical error and the same does not make
either the assessment order or the demand notice as either erroneous or in valid.



Grounds of Revenue's Appeal:
"1. On the facts and circumstances of the case, the Ld. CIT(A) erred in
not considering the fact that charging the arms length interest at 6
months LIBOR + basis points is in congruous as it leads to distortion of
the estimation of the risk assumed by the assessee."
                                         4          . / ITA No. 5109&5334/MUM/2013
                                                         [ [ /Assessment Year 2008-09




      "2. On the facts and circumstances of the case, the Ld. CIT(A) erred in
      fact and law while benchmarking the imputed interest on interest free
      loans by relying upon the RBI's Circular in respect of External
      Commercial Borrowings (ECB), which does not take into account the
      geographical perspective of the international transactions and violates
      the very spirit of Transfer Pricing Provisions."

2.    Ground No.1 of the asessee's appeal and the ground raised              by the
revenue are relating to common issue of T.P. Adjustment of Rs.18,227,199/-.
The assessee lent various amounts to its AEs as under:
S.No. Name of the AE                  Loan Given (Rs.)          Outstanding (Rs.)
1.    Ion Exchange Asia Pacific Ltd.,  10,26,772/-               10,26,772/-
      Singapore
2.    IEI Environmental Management       6,26,501/-                6,26,501/-
      Malaysia
3.    IEI Environmental Management     12,64,029/-               12,64,029/-
      Bangladesh
4.    Ion Exchange LLC, USA           1,59,00,911/-             1,59,00,911
5.    Ion Exchange & co.                  3000/-                    3000/-

2.1   The assessee in its report computed a disallowance of Rs.10,19,842/- on
account of notional interest on these loans.            While examining these
transactions for the purpose of Arms Length Price(ALP) TPO has computed the
ALP at Rs.28,47,041/- by taking interest @ 17.26%.            After reducing the
amount added by the assessee of a sum of Rs.10,19,842/- balance amount of
Rs.18,27,199/- was treated as an adjustment         on that account.      The final
analysis of adjustment made by TPO is shown in the following table which is
described at page 8 of the order of Ld. CIT(A).


Interest Offered by the assessee @LIBOR+1%(4.5           Rs.10,19,842/-
+1)%
Arm's Length Interest Rate                               Rs. 17.26% p.a.
Arm's Length Price @17.26 p.a. on loan as                Rs. 28,47,041/-
computed by the assessee.
Shortfall being adjustment u/s.92CA                      Rs. 18,27,199/-
                                            5         . / ITA No. 5109&5334/MUM/2013
                                                           [ [ /Assessment Year 2008-09



The addition was agitated in an appeal field before Ld. CIT(A).


2.2     The aforementioned rate of 17.26% has been computed by TPO based on
LIBOR+ Adjustment for credit rating of the A.E, transaction and for loan given
without security. The assessee disputed such computation on the basis that
the interest rate applied by the TPO is based on hypothetical assumption of
credit rating of the AE and assumption cost of transaction, premium over
LIBOR towards risk etc. It was pleaded that credit rating assumption by the
TPO was purely based on profit of the AE for the year under consideration as
the ratio considered by PBIT to interest. Considering such submission of the
assessee Ld. CIT(A) has found that the standalone factor adopted by the TPO
for arriving at the credit rating of    a company may not give appropriate result
as the same does not consider assets held and future prospects/business and
corresponding risk and return. Such credit rating assignment is done by the
experts taking into     account a various factors and not alone the ratio of
PBIT/interest. Accordingly, Ld. CIT(A) has held that credit rating assigned by
TPO are not acceptable and consequently the bench marking considering the
corresponding yield or interest rate for five years unsecured bond would not
be justifiable. According to Ld. CIT(A) when the money is lent the interest rates
applicable should LIBOR based          which also find support from the decisions of
ITAT.    It was observed    by Ld. CIT(A) that TPO          in his order also     has
considered even LIBOR rate and arriving at the interest rate to be charged at
LIBOR + 650 basis point + 300 basis points (transaction cost). Ld. CIT(A) has
further found that it was the submission of the assessee that loan given by the
assessee to its AE have no transaction cost and it was observed by Ld. CIT(A)
that TPO did not give any comparable circumstances to arrive at 650 basis
points more than on LIBOR and further 300 basis points on account of
transaction cost. Considering all these facts Ld. CIT(A) arrived at a finding that
suitable benchmark in the case of the assessee with regard to impugned
transaction will be the rate prescribed by RBI for ECB. Accordingly, he has
                                       6         . / ITA No. 5109&5334/MUM/2013
                                                      [ [ /Assessment Year 2008-09



given the direction to the AO to adopt LIBOR rate as per RBI's Master Circular
No.02/2007-08 dated 2/7/2007 on        External Commercial Borrowings (ECB)
provided that all in cost ceiling for ECB with average maturity period of three
years and up to 5 years is to be six months LIBOR + 150 basis points and for
period more than five years the rate is six months LIBOR +250 basis points.
Accordingly, Ld. CIT(A) directed the AO/TPO to work out the amount of
adjustment towards the interest chargeable on loans given by the assessee to
its AEs by considering rate of interest provided in the aforementioned circular
depending upon the term/period of loan given by the assessee to its AE.
Accordingly, the ground raised by the assessee was partly allowed.


2.3   The Department in its appeal is agitating the aforementioned direction
of Ld. CIT(A) and assessee in its appeal is contending that the disallowance
made by the assessee should only be made and balance disallowance should
be deleted.


2.4   We have heard both parties on this issue and we found that Ld. CIT(A)
has rightly held that according to aforementioned Master Circular issued by
RBI the ALP of impugned international transactions should be worked out. We
found that such view taken by Ld. CIT(A) has been consistently followed by
ITAT as is    observed by Ld. CIT(A) in his order.   Therefore, we decline to
interfere in such directions issued by Ld. CIT(A). Accordingly, this ground of
the assessee's appeal as well as departmental appeals are dismissed.


3.    Ground No.2 of assessee's appeal relates to disallowance made under
section 14A r.w.r. 8D.      Rule 8D is applicable w.e.f. A.Y 2008-09.      While
computing the disallowance as per rule 8D two components have been taken
into consideration.      Disallowance on account of interest is computed at
Rs.2,97,957/- and disallowance on account of expenses has been computed at
Rs.1,10,455/-.        The aggregate of both these amounts i.e. a sum       of Rs.
                                        7         . / ITA No. 5109&5334/MUM/2013
                                                        [ [ /Assessment Year 2008-09



4,08,412/- is disallowed by following Rule 8D. The total dividend received by
the assessee is a sum of Rs.9,00,459/-. The disallowance was agitated on the
ground that assessee did not incur any expenditure to earn this income. It has
been mentioned by the AO       in the assessment order that money         has cost
irrespective of whether it is ones own money or borrowed money. When one
uses borrowed money makes no real difference in as much as both of them
have cost and if they have cost, which they do have, the same would have to be
allocated to the activity for which they are utilized because they are incurred in
relation to that activity. Accordingly, the AO rejected the submission of the
assessee that no cost was incurred to earn the tax free income.                The
disallowance was agitated in an appeal filed before Ld. CIT(A). However, Ld.
CIT(A) has upheld the disallowance rejecting the contentions of the assessee.
The assessee is aggrieved, hence, has filed the aforementioned ground.


3.1   After narrating the facts, the Ld. AR submitted that assessee has
sufficient own funds to make the investment from where the tax free income
has been earned. He submitted that even current year's income is sufficient to
satisfy the investment made by the assessee as the current year's income is to
the extent of Rs.9,96,59,710/-.      Thus he submitted that no disallowance
should have been made on account of interest. So far as it relates to other
expenses   he submitted that assessee did not incur such expenditure and the
addition in its entirety should be deleted.


3.2   On the other hand, it was submitted by Ld. DR that Rule 8D is in force
for the year under consideration and, therefore, disallowance has to be
computed as per Rule-8D. Ld. Dr submitted that disallowance upheld by Ld.
CIT(A) is in accordance with law.


3.3   We have heard both the parties and their contentions have carefully been
considered. From the order of AO and Ld. CIT(A) we have found that it was
                                               8           . / ITA No. 5109&5334/MUM/2013
                                                                  [ [ /Assessment Year 2008-09



the contention of assessee that it did not incur interest expenditure for the
purpose of making investment out of which the assessee has earned tax free
income. Such contention has not been examined by either of them. Therefore,
to the extent it relates      to disallowance of interest we consider it              just and
proper to restore this issue to the file of AO with direction to re-examine the
disallowance    to that extent.      So far as it relates to another component which
relates to other expenses, we uphold the same. Accordingly, Ground No.2 is
partly allowed for statistical purposes.


4.    Apropos Ground No.3 , it was submitted by Ld. AR submitted that the
issue has to be restored back to the file of AO as similar issue was restored
back by ITAT in respect of assessment year 2005-06 and 2007-08. Reference
in this regard was made to the order dated 30/4/2013 passed in ITA No.249 &
250/Mum/2012.         The issue       has been       discussed by the Tribunal as per
following observations:-


      " 2.    Vide the first ground of appeal for both the years, the assessee contests the
      disallowance of interest imputed on interest-free advance to a subsidiary company, as
      well as the disallowance of interest on investments for acquiring controlling interest in
      such companies.

      3.      At the very outset, placing a copy of the order by the tribunal in its own case for
      an earlier year (in ITA No.7381/Mum/2007 dated 27.02.2009 for A.Y. 2004-05), it was
      submitted by the ld. AR that the said issue is arising consistently in its case since the
      past. Even the investments under reference are as made in the past and carried over as
      such. The tribunal has, in view of the decision by the apex court in the case of S. A.
      Builders Ltd. v. CIT(Appeals) (2007) 288 ITR 1 (SC), restored the matter back to the file
      of the Assessing Officer (A.O.) for consideration afresh in light of the same. On being
      enquired as to the parent order; the tribunal for A.Y. 2004-05 following its earlier order
      for A.Y. 2002-03 (in ITA No.59/Mum/2007 dated 18.12.2008), he expressed his inability
      to furnish the same, though would state that the matter in fact dates back to even an
      earlier period, i.e., A.Ys. 1997-98 and 1998-99, as would be apparent from para # 3 of
      the tribunal's order placed on record. The ld. DR, on the other hand, did not raise any
      objection to the said proposition by the ld. AR.

      4.      We have heard the parties, and perused the material on record.
      4.1 The primary facts are not in dispute. As we gather from the orders by the Revenue
      authorities, the assessee has advanced Rs.79 lakhs to its subsidiary, M/s. Ion Exchange
      Enviro Farms Ltd. (IEEFL) on interest free basis in an earlier year, which continues to
                                         9           . / ITA No. 5109&5334/MUM/2013
                                                            [ [ /Assessment Year 2008-09



outstand for the current year/s as well, claiming the said loan to be for non-business
purpose and, further, advanced from interest bearing borrowed funds. The Assessing
Officer (A.O.), thus, effected the disallowance qua interest at the average interest rate
incurred by the assessee for the relevant year/s, being at 4.85% and 3.6% p.a. for the
two successive years respectively. Apart there-from, investments worth Rs.230.53 lakhs
(for A.Y. 2005-06) and Rs.467.03 lakhs (for A.Y. 2007-08) stand made in shares for
acquiring controlling interest in subsidiary companies. In the absence of specific data in
the form of cash flow statement, or the analysis of the balance-sheet for the relevant
years, the investments have been presumed to be financed from interest bearing
borrowed funds and, accordingly, interest disallowed for the two years at Rs.11.18 lakhs
and Rs.16.81 lakhs respectively.




4.2     It is, therefore, apparent that the assessee's contention of no fresh investments
having been made for the current years, which only flow from an earlier year/s, is only
true for the first component, i.e., the interest-free advance of Rs.79 lakhs to IEEFL, a
100% subsidiary, which (advance) is from an assessment year prior to A.Y. 2001-02.
Further, the matter having been restored back by the tribunal to examine the transaction
from the stand point of commercial expediency for the earlier years, in view of the
decision by the apex court in the case of S. A. Builders Ltd. (supra), the first appellate
authority called for a report from the A.O. in the matter. The gist of the same, which
stands reproduced by him in his orders, states of the assessing authority being not
satisfied with regard to the explanation qua commercial expediency as furnished by the
assessee. No details or evidence in respect of the said subsidiary company stand
furnished, so that it was not clear as to the financial hardship being faced by the loanee
company ever since, and how could, as contended before him by the assessee, it be
considered that the same was required for - and continues to have - a stabilizing effect
on the said company. Commercial expediency could only mean furtherance of one's own
business, and not helping the assessee's sister concern, a separate company, in the
event of a mishap, i.e., even where so. With regard to the investment in the subsidiary
companies for gaining controlling interest, the assessee's claim of the same being out of
own funds is not supported, the investments having been made prior to the period for
which the cash flow statements stands submitted. In any case, the interest on these
investments was required to be capitalized inasmuch as the investment is for controlling
business interest in a subsidiary, a capital asset by definition.

4.3          The ld. AR on being questioned in the matter would state at bar that no
assessment has been made by the Revenue for A.Y. 2002-03 or in fact for any of the
years. The matter having been continuously restored back to the file of the A.O. by the
tribunal, it is incumbent for the Revenue to take a comprehensive and consistent view of
the matter. Unless there is a change in the facts and circumstances of the case, the
same view would then be required to be followed by it year after year. Secondly, the
financing pattern would have to be reviewed from year to year. This is as not only fresh
investments have been made, but also that the financing position being subject to
change, it may well be that the investment, hitherto financed by borrowed capital, gets
sourced from own funds on the influx of profits or a built-up of reserves, etc. The matter,
we may clarify, is purely factual, and the onus to establish its claim is on the assessee.

4.4    Under the circumstances, therefore, in view of the foregoing as well as in line
with the orders by the tribunal in assessee's case for the earlier years, the matter is
                                              10           . / ITA No. 5109&5334/MUM/2013
                                                                 [ [ /Assessment Year 2008-09



       restored back to the file of the A.O. for fresh adjudication after affording a reasonable
       opportunity of hearing to state its case before him. We decide accordingly. "




4.1    It was submitted that there is no difference in the facts and
circumstances of the present case as well as in the facts and circumstances of
the aforementioned assessment years.


4.2    However, Ld. DR relied upon the order passed by Ld. CIT(A).


4.3    After hearing both the parties, as it has not been pointed out that there
is any difference in facts and circumstances of the present case, and earlier
years decided by the Tribunal, respectfully following the aforementioned order,
we    restore this issue to the file of AO with similar directions as have been
given in respect of assessment year 2005-06 and 2007-08. This ground of the
assessee is treated to be allowed for statistical purposes.


5.     Ground No.4 of assessee's appeal. This issue is discussed by the AO in
para 10 of the assessment order.            The assessee borrowed loans from Exim
Bank for expansion of           Resin Manufacturing undertaking at Ankelshwar.
Referring to proviso to section 36(1)(iii) the AO observed that interest paid for
expansion of existing business has to be to be disallowed. Noting that work-in-
progress was shown at Rs.4,59,111/- the AO worked out interest cost @ 8.5%
and disallowed a sum of Rs.39,024/-.


5.1    It was submitted by Ld. AR that it has been case of the assessee that
while computing work-in-progress interest relating to borrowed                   capital was
considered in the work-in-progress and this contention of the assessee has
never been considered by the AO or Ld. CIT(A). It was submitted by Ld. AR
that this issue should be restored back to the file of AO with a direction to
examine such contention of the assessee.
                                         11         . / ITA No. 5109&5334/MUM/2013
                                                          [ [ /Assessment Year 2008-09




5.2    On the other hand, Ld. DR relied upon the order passed by Ld. CIT(A).


5.3    We have    heard both the parties and their contentions have carefully
been considered.     Since we are restoring other issues to the file of AO,
therefore, in the interest of justice this issue is also restored back to the file of
AO for re-adjudication with a direction to give appropriate opportunity to the
assessee to bring all facts on records. After bringing all facts on record, this
issue will be re-adjudicated by the AO as per law. This ground is treated to be
allowed for statistical purposes.


6.     In the result appeal filed by the revenue is dismissed and appeal filed by
the assessee is treated as partly allowed for statistical purposes.
      Order pronounced in the open court on 10/02/2014
           Û   10/02/2014                            

               Sd/-                                           Sd/-
( Û]   ãá / N.K.BILLAIYA)                            (..  / I.P. BANSAL)
  / ACCOUNTANT MEMBER                         Û  / JUDICIAL MEMBER
 Mumbai;            Dated 10/02/2014
    /Copy of the Order forwarded to :
1.  / The Appellant
2.    × / The Respondent.
3.     () / The CIT(A)-
4.      / CIT
5.     ,   ,             / DR, ITAT,
      Mumbai
6.    [  / Guard file.

                                                               / BY ORDER,
×  //True Copy//
                                       /                 (Dy./Asstt. Registrar)
                                           ,   / ITAT, Mumbai

 
 
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