IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCHES : I : NEW DELHI
BEFORE SHRI R.S. SYAL, A.M. AND SHRI A.T. VARKEY, J.M.
ITA No.2307/Del/2009
Assessment Year : 2003-04
Sumitomo Corporation India Vs. DCIT,
Private Limited, Range-9,
4th Floor, DLF Centre, New Delhi.
Sansad Marg,
New Delhi.
PAN : AABCS1887M
(Appellant) (Respondent)
ITA No.6719/Del/2013
Assessment Year : 2003-04
Sumitomo Corporation India Vs. ACIT,
Private Limited, Circle 9(1),
4th Floor, DLF Centre, New Delhi.
Sansad Marg,
New Delhi.
PAN : AABCS1887M
(Appellant) (Respondent)
Assessee by : Shri C.S. Aggarwal, Sr. Advocate,
Shri Himanshu Shekhar Sinha,
Advocate
Department by : Shri Yogesh Kumar Verma, CIT,
DR
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ITA No.6719/Del/2013
ORDER
AM:
PER R.S. SYAL, AM
These two appeals by the assessee one against quantum
and the other against penalty u/s 271(1)(c) of the Income-tax Act,
1961 (hereinafter also called `the Act') - are directed against the
separate orders passed by the ld. CIT(A) in relation to the
Assessment year 2003-04.
ITA No.2307/Del/2009 - QUANTUM
2. Briefly stated, the facts of the case are that the assessee is a
99.9% subsidiary of Sumitomo Corporation, Japan. The major
holding company is the ultimate parent company of Sumitomo
Group, which is one of the five largest trading companies of Soga
Shosha of Japan. Soga Shosha is an integrated business
enterprise with the fundamental role of facilitating trade between
buyers and sellers. Sumitomo Corporation, Japan has overseas
branches, liaison offices and other subsidiaries across the globe.
These affiliates, like the assessee, act as support centres and
render facilitation and market support services. Thus, the
assessee is a facilitator of transactions between its foreign
associated enterprises (AEs) and customers/vendors in India. The
major role of the assessee is to mediate between its AEs and
vendors/customers to/from India and also to provide information
to the AEs which helps them in taking effective business decisions
about transacting from or to India, though such decisions are
taken by such AEs alone. For rendering such services, the
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assessee gets commission on sales from the transactions in which
it mediates and also a fixed service charge for providing market
support services by making available data about Indian market
and advertisements/articles etc. from the information available in
India. Apart from rendering the said services to its AEs, the
assessee also undertook certain trading transactions at its own
during the year under consideration. The assessee reported four
types of international transactions in its audit report in Form
3CEB. There is no dispute on three international transactions.
The entire controversy revolves around the fourth one, which is a
set of international transactions of `Commission received for
trading related administrative/commercial services' for which the
assessee was allowed commission and fee totaling `
18,16,75,474/-. To benchmark this international transaction, the
assessee followed Profit Split Method (PSM) in its Transfer pricing
study by taking average of its three years' profits. Sixteen
comparable companies were chosen whose Berry ratio (ratio of
gross profit over operating expenses) was shown at 1.09% again
on the basis of three years' data. The TPO rejected the assessee's
adoption of Berry ratio; and also the use of multiple-year data
both for the assessee and sixteen comparables. He opined that
the Transactional Net Margin Method (TNMM) was the most
appropriate method to be applied by considering the data for the
current year alone. On being called upon to supply information in
this fashion, the assessee furnished its operating profit margin in
which interest on deposits amounting to ` 1,90,85,506/- was
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considered as part of its Operating revenue. The TPO held such
interest to be non-operating. He also worked out OP/TC of sixteen
comparables cited by the assessee at 9%, by considering the
current year's data alone. That is how, the TP adjustment of `
2,88,64,285/- was proposed, which was eventually made by the
AO in the assessment order passed u/s 143 (3) read with section
144C of the Act.
3. The assessee contended before the ld. CIT(A) that the
interest income should be considered as part of operating
revenue. This contention again met with the fate of rejection.
However, the ld. CIT(A) made an estimation of administrative and
other costs incurred by the assessee at ` 5 lac in making these
FDRs on which such interest income was earned. He, therefore,
directed the Assessing Officer to reduce this sum of ` 5 lac from
the overall cost/expenses taken by the TPO for the purposes of
calculating the operating profit margin. The assessee in the
present appeal is aggrieved against the exclusion of interest
income of ` 1.90 crore from operating revenue and in the
alternative and without prejudice to the main argument, on the
estimation of expenses at a meager sum of ` 5 lac.
4. We have heard the rival submissions and perused the
relevant material on record. Before proceeding further, it is
paramount to note that the ld. AR has not disputed the
application of TNMM as the most appropriate method and also the
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consideration of current year's figures alone of the assessee as
well as comparables for the purposes of determining the ALP.
5.1. Now we take up the first grievance of interest income on
FDRs vis-a-vis its inclusion or exclusion from the operating
revenue for the purposes of calculating Arm's length price (ALP)
of the international transaction under TNMM. Section 92C deals
with the computation of ALP. Sub-section (1) provides five
specific methods and one general method for the computation of
ALP. One of such methods given under sub-section (1) is TNMM.
The procedure for determining ALP under TNMM has been
enshrined in Rule 10B(1)(e) of the Income-tax Rules, 1962. For
the sake of convenience, we are reproducing the relevant part of
Rule 10B(1)(e) as under:-
`(e) transactional net margin method, by which,--
(i) the net profit margin realised by the enterprise from an
international transaction entered into with an associated
enterprise is computed in relation to costs incurred or sales
effected or assets employed or to be employed by the
enterprise or having regard to any other relevant base ;
(ii) the net profit margin realised by the enterprise or by an
unrelated enterprise from a comparable uncontrolled
transaction or a number of such transactions is computed
having regard to the same base ;
(iii) the net profit margin referred to in sub-clause (ii) arising
in comparable uncontrolled transactions is adjusted to take
into account the differences, if any, between the
international transaction and the comparable uncontrolled
transactions, or between the enterprises entering into such
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transactions, which could materially affect the amount of net
profit margin in the open market ;
(iv) the net profit margin realised by the enterprise and
referred to in sub-clause (i) is established to be the same as
the net profit margin referred to in sub-clause (iii) ;
(v) the net profit margin thus established is then taken into
account to arrive at an arm's length price in relation to the
international transaction.'
5.2. Sub-clause (i) of this Rule stipulates that the `net profit
margin' realized by the enterprise from an international taxation
is computed in relation to cost incurred or sales effected or
assets employed or to be employed or having regard to any other
relevant base. The Hon'ble Supreme Court in DIT(I.T.) VS. Morgan
Stanley & Co. (2007) 162 Taxman 165 (SC) has held that under
TNMM, it is the ratio of Operating profit to sales, cost of assets
etc. which is taken into consideration. Be that as it may, it is not
disputed that the term `net profit margin' is always construed as
`net operating profit margin' under TNMM. The essence of sub-
clause (i) of the Rule is that the net operating profit realized by
the assessee from a particular base is computed from the
international transaction, which is then compared with the net
operating profit margin realized from some comparable
uncontrolled transactions with the same base, to ascertain if the
assessee's net operating profit margin from the international
transaction is at ALP or not. It, therefore, emerges that the net
operating profit margin from the international transaction entered
into by the assessee is a first step in the process of determination
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of ALP. While calculating net operating profit margin, only those
costs and revenues are considered which directly and indirectly
affect the international transaction and are also operational in
nature. If a particular item of expenditure or income does not
affect the international transaction, the same is liable to be
rejected at the very outset. In that eventuality, the question of
the same being operating or non-operating becomes academic. It
is only if the item of income or expenditure passes the first stage,
being its relation with the international transaction, that it needs
to pass through the second stage of being operating so as to find
its place in the computation of net operating profit margin.
5.3. Excess of operating revenues over operating expenses
derived from the core business operations is called operating
income. It represents income from ordinary business activities,
and excludes expenses, such as interest, taxes and those of non-
recurring nature. In accountancy jargon, operating profit is
synonym for Earnings before interest and taxes (EBIT). All costs
associated with financing activities are excluded. Not only interest
outgo is not operating expense, the amount of interest income is
also not operating income, unless the assessee is engaged in the
business of financing activity. Albeit the interest expense is
incurred for the purpose of business (other than financing) and is
also an allowable deduction against the business income, but the
same does not assume the character of operating expense as it is
not concerned with the operations of the hub activity of business.
The same logic applies to the interest income which is also
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considered as non-operating revenue unless the business is that
of financing. The crux is that not only interest income is
construed as non-operating, but interest expenditure is also
considered as non-operating. Thus both the interest expense as
well interest income are required to be eliminated from the
purview of operating cost and operating revenue to find out the
net operating profit.
5.4. At this stage, we want to make it clear that the assessee
has been remunerated in the form of commission as percentage
of transaction value and fixed fee for providing market support
services. The commission rates are in no way related to the
incurring of any interest cost or the earning of interest income by
the assessee. We have noticed above that the assessee's role in
the international transactions is only that of mediating between
purchasers/sellers in/from India on one hand and its AEs on the
other. There is hardly any risk undertaken by the assessee or the
capital employed in so far as these transactions are concerned. As
regards the fee for market support services, the same is fixed and
does not undergo any change with or without the assessee
incurring or earning interest expenditure/income. Thus, it is
apparent that the interest income and interest expenditure of the
assessee have no role to play in the international transactions
carried out by it. Since the assessee is only a service provider in
so far as the extant international transaction is concerned and we
are required to compute net operating profit margin from such
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international transaction, the interest income, because of the
absence of its relation with the international transaction, ceases
to be eligible for consideration as income related to it, what to
talk of its inclusion in operating revenue. If we accept the
assessee's contention and treat such interest income as a part of
the operating revenue, then, the mandate of rule 10B(1)(e) of
computing `net operating profit margin' to total cost etc. of the
international transaction would be distorted.
5.5. It is further noticed that the assessee incurred interest
and finance charges and also earned interest income on deposits.
The TPO not only excluded interest income from the operating
revenue, but also did not include interest expenditure in the
operating costs to work out the net operating profit margin. The
assessee has quietly accepted the action of the TPO in not
including interest expenditure in the operating costs but is
harping on the inclusion of the interest income in the operating
revenue. Thus it can be seen that whereas the position of the
Revenue is consistent on interest expenditure as well as interest
income, the stand of the assessee is inconsistent inasmuch as it
wants the interest expenditure to be excluded from the operating
costs but the interest income continuing to form part of the
operating income.
5.6. Notwithstanding the inconsistent stand, we find that since
the international transaction under consideration is not that of
financing, naturally, interest income and interest expenditure
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cannot be construed as the items of operating nature. At this
juncture, it would be in the fitness of things to note the judgment
of the Hon'ble jurisdictional High Court in Marubeni India Pvt. Ltd.
vs. DCIT (2013) 354 ITR 638 (Del). In that case also, the assessee
contested the action of the AO in excluding the interest income
from the operating revenue. The Tribunal approved the view of
the authorities that the interest was not operating income. When
the matter came up before the Hon'ble High Court, their
Lordships affirmed the view taken by the Tribunal. The ld. AR was
fair enough to concede that the question of exclusion of interest
income has been decided by the Hon'ble High Court against the
assessee, but he claimed that it was not rule of universal
application. He emphasized that the interest income in the
present circumstances was different from the one that was
considered by their Lordships and, hence, the same should be
considered as a part of operating income. It was also accentuated
that the instant interest income was in the nature of `Business
income' and not `Income from other sources', which factor makes
its case distinguishable.
5.7. We find no reason to countenance the contention put forth
on behalf of the assessee for two reasons. First is that interest in
the present circumstances is not in the nature of `Business
income'. If we scrutinize the detail of interest earned on FDRs,
which is available on pages 222 and 223 of the paper book, it is
overt that there are three items of interest income totaling to
Rs.5,251 on FDRs under lien with Sales-tax Department, as
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against the total interest income of Rs.1.90 crore. Apart from
that, there is no mention of any business purpose for which such
FDRs were made. The TPO has recorded that the balance of time
deposits in the assessee's balance sheet as on 31.3.03 stood at `
26.38 crore on which such interest income of ` 1.90 crore was
earned. The TPO further observed that the balance of time
deposits was at Rs.25.14 crore and Rs.24.15 crore on 31.3.2002
and 31.3.2001 respectively. In the light of these figures of
investment in FDRs in the same range over the years, the TPO
held that the assessee was continuously investing its surplus
funds which were renewed from time to time. The ld. AR opposed
this contention by arguing that the number of days for which the
FDRs were made was as low as three days in some cases, which
extended to a larger period in others. In our considered opinion,
the number of days for which FDRs were made by the assessee is
not decisive for determination of the character of interest income
in the hands of the assessee as to whether it is operating or non-
operating income. From the above factual narration, it is evident
that in so far as interest of Rs.5,251/- is concerned, the same is
emanating from FDRs under lien with the Sales-tax Department,
which divulges that the same is linked with the domestic
transactions with the unrelated parties and has absolutely no
connection with the international transactions. As regards the
balance interest of Rs.1.89 crore and odd, such FDRs are
inferred to have been made out of surplus funds as the assessee
failed to demonstrate any direct link between international
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transactions and the making of FDRs on which such interest
income was earned. Ex consequenti, such interest income
cannot be held as anything other than `Income from other
sources.'
5.8. The second reason for not approving this contention is that
the question as to whether interest is `Business income' or not is
irrelevant when the point for determination is the amount of
operating profit margin. Operating profit margin is obviously a
part of the overall profit margin which is deduced by reducing
non-operating expenses and non-operating incomes from the net
profit. The Hon'ble High Court in Marubeni India (supra) has dealt
with such contention of the interest income being in the nature of
business income because of the Memorandum of Association
permitting the making of investment. In this regard, the Hon'ble
High Court has held that : `The Tribunal has rightly noted that the
fact that the memorandum of association gave powers to the
assessee to earn interest by making investments is relevant only
for the purpose of determining the appropriate head of income
under section 14 of the Income Tax Act, 1961 under which the
interest would fall to be assessed. It has been rightly observed by
the Tribunal that such a consideration is not relevant for the
purpose of determining the operating income of an assessee for
the purposes of transfer pricing regulations.' In view of the
foregoing discussion, we find the contention of the ld. AR devoid
of merits on both the counts, viz., first that the interest is
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Business income and second because of the same being so,
should per se be considered as operating income.
5.9. Another attempt was also made by the ld. AR to convince
us, by arguing that the interest was earned by investing working
capital and not equity capital and hence the interest be treated as
operating income. We are again unable to comprehend as to how
this contention alters the character of interest income from non-
operating to operating. As the assessee is not in the financing
activity with its AEs, but, rendering only mediatory and support
services, we hold that interest earned from investing working
capital service cannot first qualify as income from such
international transactions and then at any rate it is not a
operating income. This contention raised on behalf of the
assessee is therefore, repelled.
6.1. The next alternative point espoused by the ld. AR was
against allowing deduction for a meager sum of ` 5,00,000/- by
the ld. CIT(A) towards administrative and other costs incurred in
making these FDRs yielding interest income. The ld. AR
contended that this ad hoc estimate made by the CIT (A) was not
sustainable. On a specific query from the Bench, the ld. AR could
not give any other alternative viable way to determine the
amount of expenses incurred for earning interest of FDRs. As the
Revenue has accepted this finding given by the ld. CIT(A) for
allowing such deduction of ` 5 lac by not filing any cross appeal,
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we cannot accept the contention of the ld. DR that no deduction
was called for. Now the limited point before us is to examine as
to whether this estimated amount of ` 5 lac as deduction for
allowing deduction towards administrative and other costs is
appropriate.
6.2. Though there is no mechanism provided in the Act to find
out such administrative and other costs incurred in making the
FDRs on which the interest income is earned, we find some hint
from the prescription of section 14A of the Act which deals with
not allowing any deduction for the expenditure incurred in
relation to income not includible in the total income. Rule 8D has
been enshrined in the Income-tax Rules as a measure for
determining the amount of expenditure in relation to income not
includible in the total income. Clauses (i) and (ii) of Rule 8D (2)
deal with the amount of expenditure directly relating to income
including interest. Clause (iii) provides for the amount equal to
0.50% of the average of the value of investment towards other
expenses. It is sum total of these components which is disallowed
u/s 14A read with Rule 8D.
6.3. We have noticed above that the TPO has not included any
interest expenditure in operating expenses. Further, the assessee
has also failed to point out any direct expenditure in this regard.
Thus there can be no analogous figure of direct and interest
expenditure in consonance with clauses (i) and (ii). Then comes
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clause (iii), which deals with other expenses. As we have to
presently calculate a reasonable amount of administrative and
other costs incurred in making these FDRs on which interest
income was earned, it is the prescription of clause (iii) of Rule
8D(2) which renders some guidance and can be taken assistance
of. The TPO has recorded that the amount of investments in time
deposits as on 31.3.03 stands at ` 26.38 crore. If we apply ½% of
such value of investment, then, the administrative and other
costs comes to ` 13.19 lac. In our considered opinion, it would be
just and fair to apply this logic in working out the amount of
administrative and other costs incurred by the assessee in
making FDRs on which the interest income was earned. That
being the position, there would result the deductible amount of
Rs.13.19 lac against the impugned order granting deduction of ` 5
lac. We, therefore, hold that operating expenses be reduced by
this extent.
7.1. The only other point agitated by the ld. AR in this appeal is
against the inclusion of the case of Samrat Clearing in the list of
comparables. The facts apropos this issue are that the assessee
submitted a list of sixteen comparables which, inter alia, included
Samrat Clearing. The TPO did not tinker with such list of
comparables and proceeded to determine the ALP accordingly.
Now, the assessee is contesting the inclusion of this case in the
list of comparables by stating that it was originally included by
inadvertence. The contention was sought to be supported by
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arguing that the relevant data in respect of income and
expenditure of the aforesaid case was not properly available in
the public domain. The only thing available was its Profit & Loss
Account with sales/operating income at ` 9 lac. The ld. AR
contended that the TPO himself excluded this case in the
immediately succeeding year on the ground of low turnover. It
was, therefore, prayed that this case be expelled from the list of
comparables. The ld. DR opposed the contention advanced on
behalf of the assessee by submitting that this issue was not
raised before the TPO and it was too late in the day to argue
before the Tribunal for eliminating this case from the list of
comparables.
7.2. We are not agreeable with the view canvassed by the ld.
DR that this case cannot be considered at this stage for the
purposes of exclusion because no such issue was raised before
the TPO. The Special Bench of the Tribunal in the case of DCIT vs.
Quark Systems Pvt. Ltd. (2010) 132 TTJ (Chd) (SB) 1 has held that
a tax payer cannot be estopped from pointing out a mistake
committed by it in including a case as comparable, which was in
fact not so. Various Benches of the Tribunal have followed this
Special bench verdict in permitting the assessees to raise an
issue for the exclusion of a particular case which was
inadvertently included in the transfer pricing study. As such, we
do not find any merit in the preliminary objection raised by the ld.
AR on this issue.
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7.3. Coming to the merits of the exclusion or otherwise of
this case, we find that there is no discussion in the order of the
TPO about the comparability or otherwise of this case with the
assessee. In our considered opinion, the ends of justice would
meet adequately if the impugned order is set aside to this extent
and matter is restored to the TPO/AO for first deciding the
comparability or otherwise of Samrat Clearing with the assessee
and then accordingly recomputing the ALP of this set of
international transactions. Needless to say, the assessee will be
allowed a reasonable opportunity of being heard in such
proceedings.
8. In the result, the appeal is partly allowed.
ITA No.6719/Del/2013 PENALTY U/S 271(1)(c)
9. The assessee, vide this appeal, is aggrieved against
confirmation of penalty amounting to ` 1,05,23,735/- imposed by
the AO u/s 271 (1)(c) of the Act. The AO imposed the penalty with
reference to the transfer pricing addition as reduced pursuant to
the order passed by the ld. CIT (A) in quantum proceedings. The
said penalty came to be upheld by the impugned order. The
assessee is aggrieved against the imposition of this penalty.
10. After considering the rival submissions and perusing the
relevant material on record, we find that there are basically three
issues involved in the quantum appeal, viz.,
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(i) Exclusion of interest income of ` 1.90 crore from the
operating revenue;
(ii) Deduction of administrative expenses incurred in
relation to such interest income; and
(iii) Reconsideration of the comparability or otherwise of
the case of Samrat Clearing with the assessee.
11. After deciding the first issue of the exclusion of interest
income from the operating revenue against the assessee and the
second issue partly in favour of the assessee by holding that
deduction for administrative and other costs should be allowed at
` 13.19 lac as against ` 5 lac allowed by the ld. CIT (A), we have
remitted the matter to the TPO/AO for considering as to whether
the case of Samrat Clearing is comparable with that of the
assessee. If it turns out to be not comparable, then the same
should be excluded from the list of comparables and fresh
determination of the operating profit margin of the remaining
comparables be done to ascertain if any transfer pricing
adjustment is warranted. In view of the fact that we have sent
the matter back to the file of AO/TPO for a fresh determination of
addition which constitutes the bedrock of the present penalty,
the fate of penalty cannot be decided at this juncture. The
Hon'ble Supreme Court in the case of Mohd. Mohatram Faruqui
vs. CIT (SC) 2010 TIOL 23 SC IT has held that where the addition
has been restored to the AO, the penalty should also be restored
for taking a fresh decision in accordance with the view finally
taken in the quantum proceedings. We, therefore, set aside the
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impugned order and remit the matter to the file of the AO for
deciding the question of penalty afresh after taking decision in
the quantum proceedings about the addition, if any, on account of
transfer pricing adjustment.
12. Before parting with this appeal, we would like to record that
the ld. AR made marathon arguments urging us to render decision
in his favour on the question of penalty u/s 271(1)(c) of the Act
with reference to the interest income from FDRs. He strenuously
argued that no penalty was exigible on this score.
13. We are not convinced with the proposition put forth on
behalf of the assessee that a decision must be rendered on the
maintainability or otherwise of penalty on the exclusion of interest
income from the operating revenues. The obvious reason for our
this decision is that the amount of interest income is not subject
matter of addition on which penalty has been imposed. There is
no doubt that the assessee did offer this amount as income. It is
only while calculating the assessee's margin of profit that the
TPO came to the conclusion that the amount of interest is not
liable to be included in the operating income as was done by the
assessee. The overall impact of the decision of the TPO on this
issue ultimately got reflected in the final transfer pricing
adjustment proposed by him. There is hardly any need to
emphasize that penalty u/s 271(1)(c) is always imposed with
reference to the amount of tax sought to be evaded, which, in
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turn, finds its foundation from the ultimate addition. The effect of
our decision in restoring the matter to the TPO/Assessing Officer
is that the amount of addition and the resultant amount of tax
sought to be evaded cease to exist for the time being. The
possibility of deletion or reduction in the transfer pricing addition
in the fresh proceedings cannot be ruled out. It is quite possible
that notwithstanding the exclusion of interest income from the
operating profits, there may still not be any TP addition, if the
overall profit rate of the finally chosen comparables is found to be
within the safe harbor margin vis-a-vis that of the assessee.
Since the addition does not stand as of now, it is too early to ask
for our decision on an aspect of the matter, whose impact on the
addition is unknown. Ergo, we are disinclined to give any decision
on the question of penalty at this juncture.
14. In the result, the appeal is allowed for statistical purposes.
The order pronounced in the open court on 11.06.2014.
Sd/- Sd/-
[A.T. VARKEY] [R.S. SYAL]
JUDICIAL MEMBER ACCOUNTANT MEMBER
Dated, 11th June, 2014.
dk
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Copy forwarded to:
1. Appellant
2. Respondent
3. CIT
4. CIT (A)
5. DR, ITAT
AR, ITAT, NEW DELHI.
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