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Capital Gains: Enhanced compensation received - Year of taxability: Law applicable
May, 07th 2008

Chandi Ram vs CIT
Citation 168 Taxman 315 
 
Capital Gains: Enhanced compensation received - Year of taxability: Law applicable

The assessee's land had been compulsorily acquired. He was awarded additional compensation by the District court. However, 50 percent of the additional compensation was received on furnishing security till the final decision in appeal against court's order was passed. Since the final payment of enhanced compensation was under challenge, the compensation received as per interim order was not taxable as per s.45(5)(b). S.45(5)(c) and s.155(16) interested w.e.f. 1 April 2004 were prospective and so applicable only from AY 2004-05. S.45(5)(c) was not clarifactory. The entire amount of additional compensation received was not taxable in the impugned years.

High Court of Punjab and Haryana

Chandi Ram vs CIT

IT Appeal Nos. 4 to 7 of 2005, 415 to 417 and 433 to 438 of 2007

Satish Kumar Mittal and Rakesh Kuamr Garg, JJ

25 February 2008

Sanjay Bansal, Parveen Saini, Parshant Bansal, Avneesh Jhingan and Vijay Gupta for the Appellant
Yogesh Putney for the Respondent

JUDGMENT

Satish Kumar Mittal, J - These appeals have been filed by the assessees against the order passed by the Income-tax Appellate Tribunal, Delhi Bench 'E', Delhi (hereinafter referred to as 'the Appellate Tribunal'), whereby it has been held that the entire amount of additional compensation as received by the assessees on the basis of the Award given by the District Judge will be liable to be considered for the purpose of computation of capital gain under section 45 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'), in the year of its receipt, irrespective of the fact that 50 per cent amount of the additional enhanced compensation was received on furnishing security in terms of the interim order passed by the Appellate Authority till the final decision of the appeal filed by the State, challenging the award of enhancing the additional compensation.

2. The appellants have questioned the aforesaid decision of the Appellate Tribunal on the ground that it has failed to consider the basic fact that the amount of additional compensation received by the assessee under the interim order of the Appellate Court on furnishing security cannot be considered to have been received by the assessee in the year of receipt, which has not become final and against which the appeal is pending. The expression 'received' as existing in section 45(5)(b) of the Act would mean received in pursuance of the accrual of right to receive as a result of or in consequence of a decision given by a Court, Tribunal or Authority settling the lis between the claimant and the State finally. The word 'Received' cannot be given a meaning of physical receipt of additional compensation without any right or title conferred upon the claimant by the adjudicatory process of the Court, Tribunal or Authority. According to the appellants, the additional compensation is considered to be received in the meaning of section 45(5)(b) of the Act, not when the additional compensation was actually received under the interim order of the Court subject to furnishing security and subject to the final decision of the Appellate Authority, but it will be considered to be received on the date the dispute is finally decided by the Appellate Court. Therefore, the additional compensation awarded in such situation cannot be assessed in the year in which it was actually received. Therefore, the appellants have made the prayer that the Tribunal has erred in law while holding that the provisions of section 45(5)(b) of the Act were attracted to the case of the appellants herein, and have raised the following substantial questions of law which are arising from the order of the Tribunal for consideration/adjudication by this Court :

"(i) Whether on a proper and correct interpretation of the provisions of section 45(5)(b) of the Income-tax Act, 1961, the Tribunal was right in law in holding that the amount of additional compensation received by the assessees, appellants herein, in pursuance of the interim orders subject to furnishing of security would be deemed to be the income for the purpose of computation of capital gain in the year of receipt of such amounts?

(ii) Whether the Tribunal was correct in holding that the amount received by the assessees fell within the ambit of section 45(5)(b) of the Income-tax Act, 1961 as the decision rendered by the Hon'ble Supreme Court in the case of CIT v. Hindustan Housing and Land Development Trust Ltd. [1986] 161 ITR 524/27 Taxman 450A no longer holds the field?'

The IT Appeal Nos. 4 to 7 of 2005 were admitted on 10-8-2006, to be heard with ITA No. 322 of 2004, in which the following question of law was framed :-

"Whether the Hon'ble ITAT was justified in applying the ratio laid down in the case of CIT v. Hindustan and Land Development Trust Ltd. [1986] 161 ITR 524/27 Taxman 450A in the present case even after insertion of section 45(5) in the Income-tax Act specifically for charging of enhanced compensation in the year of receipt?'

It is pertinent to mention here that the revenue filed appeals against several decisions of the Appellate Tribunal, wherein while applying the ratio laid down in the case of CIT v. Hindustan Housing and Land Development Trust Ltd. [1986] 161 ITR 5241 and various other decisions of the different High Courts, including the Karnataka High Court in the case of Chief CIT v. Smt. Shantavva [2004] 267 ITR 672, it was held that section 45(5)(b) would be attracted only when the assessee receives the enhanced compensation in pursuance of final Award/order of a Court, Tribunal or other authority increasing the compensation and not on the actual receipt of the said amount under the interim order passed by the Appellate Court. All those appeals filed by the revenue, i.e., IT Appeal No. 322 of 2004 and other connected appeals were dismissed by this Court in CIT v. Shri Prem Singh [ITA No. 695 of 2005 decided on 16-5-2007], while observing as under :-

"At the outset, learned counsel for the assessee contended that the question of law raised in the present appeals is squarely covered by the decision of this Court in ITR No. 26 of 1997, the CIT v. Shri Karanbir Singh, Rajinder Kuti, Patiala, decided on 17-1-2007, as these appeals also involved the same question of law as has been decided in the aforesaid case (supra).

However, Mr. Putney, learned counsel appearing for the revenue has contended that amendment in section 45(5) of the Income-tax Act, 1961 (for short 'the Act') has not been noticed in the said judgment.

We are afraid that the contention of learned counsel for the revenue is not correct as the Division Bench has specifically noticed the judgment of Karnataka High Court in case of Chief CIT v. Smt. Shantavva [2004] 267 ITR 67/136 Taxman 678, wherein the amendment inserted to section 45(5) of the Act had been specifically dealt with and the similar question, as has been raised in these appeals, was decided against the revenue and in favour of the assessee. We have also perused the judgment rendered in Bikram Singh v. Land Acquisition Collector [1997] 224 ITR 551/[1996] 89 Taxman 119 (SC).

After going through the abovereferred to decisions, we are of the considered view that question raised in the present appeals is squarely covered by the aforesaid decisions.'

It is also pertinent to mention here that in all the aforesaid appeals filed by the revenue, the additional enhanced amount of compensation actually received was pertaining to the assessment years 1994-95 to 1998-99. While dismissing the appeals of the revenue, another Division Bench decision of this Court in CIT v. Shri Karanbir Singh, Rajinder Kuti [ITR No. 26 of 1997, dated 17-1-2007], was followed.

3. Shri Sanjay Bansal, learned senior counsel for the appellant-assessee submitted that the substantial questions of law involved in these appeals are squarely covered by the abovesaid two decisions rendered by this Court Shri Karanbir Singh, Rajinder Kuti's case (supra) and Shri Prem Singh's case (supra), in which judgments of the Supreme Court in Bikram Singh v. Land Acquisition Collector [1997] 224 ITR 5511 and of the Karnataka High Court in the case of Smt. Shantavva (supra), were followed. Those cases have been decided in favour of the assessee and against the revenue. Therefore, the Appellate Tribunal was not justified in law in taking a view contrary to the view taken by the Karnataka High Court and this Court. Learned counsel further submitted that the aforesaid view taken by two Division Benches of this Court, following the view taken by the Karnataka High Court has been taken by various other High Courts in the following cases :

(i) CIT v. Jeevan and Sons [2000] 161 CTR (Raj.) 242;

(ii) Darapaneni Chenna Krishnayya (HUF) v. CIT [2007] 291 ITR 98 (AP);

(iii) CIT v. Dehradun Tea Co. [2007] 291 ITR 212 (Uttarakhand);

(iv) CIT v. Abdul Mannan Shah Mohommed [2001] 248 ITR 614 (Bom.);

(v) CIT v. C.P. Lonappan and Sons [2004] 265 ITR 101 (Ker.);

(vi) CIT v. Laxman Dass [2000] 246 ITR 622 (All.);

(vii) Anil Kumar Forma (HUF) v. CIT [2007] 289 ITR 245 (Mad.).

4. On the other hand, Mr. Yogesh Putney, Advocate, learned counsel for the revenue submitted that neither in the case of Karnataka High Court in Smt. Shantavva (supra) nor in the Division Bench decisions of this Court in Shri Prem Singh's case (supra) and Shri Karanbir Singh, Rajinder Kuti's case (supra) or any other judgment cited by learned counsel for the appellants, the effect of provision of clause (c) of section 45 (5) of the Act and sub-section (16) of section 155 of the Act, which were inserted by the Finance Act, 2003 with effect from 1-4-2004, was considered. However, both these provisions have been taken into consideration by the learned Appellate Tribunal, while passing the impugned order.

5. For ready reference, both the aforesaid provisions are reproduced herein below :-

"45(5)(c) wherein the assessment for any year, the capital gain arising from the transfer of a capital asset is computed by taking the compensation or consideration referred to in clause (a) or, as the case may be, enhanced compensation or consideration referred to in clause (b), and subsequently such compensation or consideration is reduced by any court, Tribunal or other authority, such assessed capital gain of that year shall be recomputed by taking the compensation or consideration as so reduced by such Court, Tribunal or other authority to be the full value of the consideration.

155(16) wherein the assessment for any year, a capital gain arising from the transfer of a capital asset, being a transfer by way of compulsory acquisition under any law, or a transfer, the consideration for which was determined or approved by the Central Government or the Reserve Bank of India, is computed by taking the compensation or consideration as referred to in clause (a) or, as the case may be, the compensation or consideration enhanced or further enhanced as referred to in clause (b) of sub-section (5) of section 45, to be the full value of consideration deemed to be received or accruing as a result of the transfer of the asset and subsequently such compensation or consideration is reduced by any Court, Tribunal or other authority, the Assessing Officer shall amend the order of assessment so as to compute the capital gain by taking the compensation or consideration as so reduced by the Court, Tribunal or any other authority to be the full value of consideration; and the provisions of section 154 shall, so far as may be, apply thereto, and the period of four years shall be reckoned from the end of the previous year in which the order reducing the compensation was passed by the Court, Tribunal or other authority.'

6. Mr. Putney submitted that the main section under which the capital gain is charged to tax is sub-section (1) of section 45 of the Act. As per the scheme of the said section, capital gain is to be brought to tax 'in the year in which the transfer takes place'. However, during the course of time, difficulties were faced by the revenue in realising tax on enhanced compensation awarded by the Courts in appellate proceedings. In order to remedy those difficulties, sub-section (7A) of section 155 of the Act was introduced by the Finance Act, 1978, with retrospective effect from 1-4-1974. However, the said amendment also did not serve the purpose and therefore, sub-section (7A) was omitted with effect from 1-4-1988. Thereafter, sub-section (5) of section 45 of the Act was added vide Finance Act, 1987, with effect from 1-4-1988 to charge the compensation enhanced or further enhanced. However, even this provision was not adequate to deal with the situation where the enhanced compensation was reduced on appeal. Therefore, clause (c) in sub-section (5) of section 45 of the Act was inserted by Finance Act, 2003 with effect from 1-4-2004, which provides that "where in the assessment for any year, the capital gain arising from the transfer of a capital asset is computed by taking the compensation or consideration referred to in clause (a) or, as the case may be, enhanced compensation or consideration referred to in clause (b), and subsequently such compensation or consideration is reduced by any Court, Tribunal or other authority, such assessed capital gain of that year shall be recomputed by taking the compensation or consideration as so reduced by such Court, Tribunal or other authority to be the full value of the consideration.' Learned counsel further submitted that for re-computation of capital gain in case of reduction in compensation, a new sub-section (16) in section 155 of the Act was also inserted by the Finance Act, 2003, with effect from 1-4-2004, to provide that the Assessing Officer shall amend the order of assessment to revise the computation of said capital gain of that year by taking the compensation or consideration so reduced by the Court, Tribunal or other authority to be the full value of consideration. Learned counsel submitted that very scheme of introduction of sub-section (5) to section 45 of the Act was to bring to charge the compensation on receipt basis. Therefore, there is no justification for ignoring of assessment of enhanced compensation on receipt basis. Learned counsel submitted that the enhanced compensation is to be assessed in the year in which it is actually received. He submitted that now clause (c) of sub-section (5) of section 45 read with sub-section (16) of section 155 of the Act automatically takes care of the situation where the enhanced compensation is subsequently reduced by any Court, Tribunal or other authority. He submitted that clause (c) which was inserted with effect from 1-4-2004 was only a declaratory in character, therefore, it will apply retrospectively. Thus, even in case of the appellants, where the cases pertain to the assessment years 1994-95 to 1998-99, the further enhanced compensation, even if the same was received on the basis of the interim order passed by the Appellate Court, will be taxed in the year in which it was actually received and not on the date the dispute is finally decided by the Appellate Court. He submitted that the provision of clause (c) of section 45(5) of the Act is not substantive but procedural and clarificatory in nature as it only takes into consideration the law as it stood even prior to that, therefore, these provisions will apply retrospectively. He submitted that the rule of retrospectivity has to apply to the procedural amendment.

7. On the other hand, Shri Sanjay Bansal, learned counsel for the appellants-assessees submitted that the right to receive compensation is essential to tax enhanced compensation. A non-operative, non-effective, non-enforceable order or decree on account of stay or conditions imposed by superior Court cannot give rise to any chargeable income. The income must accrue or arise before it can be brought to tax under the Act. The expression "received' as existing in section 45(5)(b) of the Act mean received in pursuance of the accrual of right to receive as a result of or in consequence of a decision given by a Court, Tribunal or Authority settling the lis between the claimant and the State. Learned counsel submitted that the expression "received' cannot be given a meaning of physical receipt of additional compensation without any right or title conferred upon the claimant by the adjudicatory process of the Court, Authority or Tribunal. "Received' means lawfully received or received under a legal title. He submitted that the enhanced compensation received under the conditional order of the court cannot be taken as income received because the order is liable to be varied, reversed or set aside. Such temporary arrangement cannot give rise to "accrual' of income. Learned counsel submitted that as far as application of clause (c) of section 45(5) and sub-section (16) of section 155 of the Act, which were inserted by Finance Act, 2003 is concerned, these clauses will not be applicable and taken into consideration while deciding the present appeals, which pertain to the assessment years 1994-95 to 1998-99, because these provisions are prospective and made applicable with effect from 1-4-2004 and will only apply in relation to the assessment year 2004-05 and subsequent years. Learned counsel further submitted that sub-section (5) of section 45 including clauses (a) (b) and (c) is a substantive provision and is a charging section, therefore, any part of this sub-section cannot be made applicable retrospectively.

8. We have considered the submissions made by learned counsel for the parties and have also perused the impugned order as well as the various judgments cited by learned counsel for the parties.

9. Section 45 of the Act provides for charging of capital gain and such profits and gains shall be deemed to be the income of the previous year, in which transfer took place. Subsequently, when the department had to face difficulties in realising capital gains arising on compensation by courts at different stages i.e., at the level of District Judge, High Court and the Supreme Court, the legislation introduced sub-section (5) to section 45 with effect from 1-4-1988. Vide this sub-section, the enhanced compensation was brought to charge to capital gain in the year in which it was received. Prior to this, where capital gains accrue or arise by way of compensation, the additional compensation is taken into consideration for determining the capital gain for the year in which transfer took place. To provide for rectification of assessment of the year in which the capital gain was originally assessed, section 155(7A) was introduced. The additional compensation was awarded in several stages by different appellate authorities. That necessitates rectification of the original assessment at each stage. This again caused great difficulty in carrying out the required rectification and in effecting the recovery of additional demand. With a view to remove these difficulties, a new sub-section (5) to section 45 was inserted which provides for taxation of additional compensation in the year of receipt instead of in the year of transfer of the capital asset. This provision was interpreted by various High Courts as well as by this Court and it has been held that section 45(5)(b) of the Act would be attracted only when the assessee receives the enhanced compensation in pursuance of a final award/order of a Court, Tribunal or other authority increasing the compensation. If any amount is received after stay of the award, in pursuance of any interim order, as payment subject to the final result, it will not be an amount received as enhanced compensation under section 45(5)(b). This provision will be attracted only when the final decision is rendered by the Appellate or other Authority. In these decisions, the decision of the Supreme Court in Hindustan Housing and Land Development Trust Ltd.'s case (supra) was constantly followed. We do not see any reason to have a contrary view to these judgments, which have already been followed by this Court in Shri Karanbir Singh, Rajinder Kuti's case (supra) and Shri Prem Singh's case (supra).

10. In these appeals, learned counsel for the revenue has argued that the two provisions i.e. clause (c) of section 45(5) and sub-section (16) of section 155 of the Act, which have been inserted by the Finance Act, 2003 and which have changed the entire dimension, have not been considered. After the introduction of these two provisions, the view taken by this Court and the other Courts in the aforesaid judgments is not sustainable. It is the case of the revenue that both these provisions are procedural in nature, therefore, these will be applicable retrospectively, and thus will also be applicable in the cases in hand, which pertain to the assessment years 1994-95 to 1998-99.

11. We do not find any substance in the aforesaid argument raised by learned counsel for the revenue. Clause (c) to section 45(5) and sub-section (16) to section 155 of the Act have been inserted by the Finance Act, 2003, with effect from 1-4-2004. The Notes on these clauses which have been published in (2003) 260 ITR 166 clearly state that these amendments will take effect from 1-4-2004 and will, accordingly, apply in relation to the assessment year 2004-05 and subsequent years. Clause (c) to section 45(5) of the Act was inserted to provide that where the amount of the compensation is subsequently reduced by any Court, Tribunal or other authority, the capital gain of that year, in which the compensation received was taxed, shall be recomputed accordingly. Sub-section (16) to section 155 of the Act was inserted empowering the Assessing Officer to amend the order of assessment to revise the computation of said capital gain of that year by taking into consideration the compensation, so reduced by the authority. Actually, these provisions were inserted to meet the situation when compensation is subsequently reduced and in that situation, it was provided that the assessment of additional compensation is to be reduced in the year of reduction. We are unable to accept the reasoning given by the Special Bench of the Tribunal that clause (c) to sub-section (5) of section 45 of the Act inserted by Finance Act, 2003 is to be made applicable retrospectively, and taken to be introduced with effect from 1-4-1988. It has been observed that this clause was inserted to make the entire scheme workable and to supply an obvious omission in the provision. Therefore, the said clause has to be taken to be declaratory in character and is applicable with retrospective effect. In our opinion, the entire sub-section (5) of section 45 of the Act is a charging section. The said sub-section itself is a code and contains substantive provisions. Therefore, its provisions cannot be made applicable retrospectively without any express indication. Clause (c) to section 45(5) was inserted by Finance Act, 2003 with effect from 1-4-2004. In the purpose clause, it was specifically stated that this amendment will take effect from 1-4-2004 and will, accordingly, apply in relation to the assessment year 2004-05 and subsequent years. Similarly, sub-section (16) to section 155 of the Act was introduced with effect from 1-4-2004 and as per Note [published in (2003) 260 ITR 166] the amendment was to apply in relation to the assessment year 2004-05 and subsequent years. If the legislation wanted to insert these clauses with retrospective effect, it could have been so stated in the Amending Act. Previously, when sub-section (7A) to section 155 of the Act was inserted by Finance Act, 1978, it was specifically mentioned that it was inserted with retrospective effect from 1-4-1974. If the legislation wanted to insert these clauses with retrospective effect, it could have been so mentioned in the Amending Act, but when specifically the legislation has mentioned that these clauses have been inserted with effect from 1-4-2004 and will be applicable in relation to the assessment year 2004-05 and not prior to that, then these clauses cannot be given retrospective operation merely on the ground that these are declaratory in character. It is settled law, as has been held in Virtual Soft Systems Ltd. v. CIT [2007] 289 ITR 831 (SC), that a taxing provision imposing liability is governed by the normal presumption that it is not retrospective. There is no assumption as to the retrospectivity of an amendment. Retrospectivity has to be enacted specifically in the fiscal statute. Regarding considering an amendment to be declaratory or clarificatory, in this judgment it has been observed as under :

". . . It is the well-settled legal position that an amendment can be considered to be declaratory and clarificatory only if the statute itself expressly and unequivocally states that it is a declaratory and clarificatory provision. If there is no such clear statement in the statute itself, the amendment will not be considered to be merely declaratory or clarificatory.

Even if the statute does contain a statement to the effect that the amendment is declaratory or clarificatory, that is not the end of the matter. The court will not regard itself as being bound by the said statement made in the statute but will proceed to analyse the nature of the amendment and then conclude whether it is in reality a clarificatory or declaratory provision or whether it is an amendment which is intended to change the law and which applies to future periods. . . .' (p. 106)

12. In the present case, it may be noted that amendment to section 45 of the Act by inserting clause (c) by the Finance Act, 2003 only states that the amended provision would come into force with effect from 1-4-2004. The statute nowhere states that the said amendment was either clarificatory or declaratory. On the contrary, in the Note [published in [2003] 260 ITR 166], it was clearly stated that this amendment would come into force with effect from 1-4-2004 and will be applicable on the assessment year 2004-05. Therefore, we are of the opinion that these amendments would apply only to future period and not to any period prior to 1-4-2004 or any assessment year prior to the assessment year 2004-05.

13. In the present cases, the dispute relates to the assessment years 1994-95 to 1998-99 and during that period, only section 45(5)(b) of the Act was applicable, which has already been interpreted by this Court and various other Courts, wherein it has been clearly held that section 45(5)(b) will be attracted only when the assessee receives the enhanced compensation in pursuance of a final award/order of a court, Tribunal or other authority increasing the compensation. If any amount is received after stay of the award, in pursuance of any interim order, as a payment subject to the final result, it will not be an amount received as enhanced compensation as contemplated under section 45(5)(b), but only an interim payment received subject to final decision. Since this Court has already taken the view, therefore, in our opinion, the Tribunal was not justified in taking contrary view to the view taken by this Court in Shri Karanbir Singh, Rajinder Kuti, Patiala's case (supra) and Shri Prem Singh's case (supra), by following the decision of the Karnataka High Court in the case of Smt. Shantavva (supra).

14. Consequently, the impugned order is not sustainable and all these appeals are accordingly allowed. The substantial questions of law are, thus, answered in favour of the assessees and against the revenue.

 
 
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