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From the Courts »
 CIT vs. ITD CEM India JV (Bombay High Court)
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  H.T. MEDIA LIMITED Vs. PRINCIPAL COMMISSIONER OF INCOME TAX-IV, NEW DELHI
 Commissioner Of Income Tax (Ltu), New Delhi Vs. Oriental Insurance Company Ltd.
 Principal Commissioner Of Income Tax (Central)-2 Vs. Index Securities Private Limited
 Income Tax Appellate Tribunal, Ahmedabad Benches, Ahmedabad Constitution For The Period From 18/09/2017 To 22/09/2017
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  Commissioner Of Income Tax, Delhi-Iv Vs. DLF Universal Ltd.
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 Jcb India Ltd. Vs. Deputy Commissioner Of Income Tax &
 Saheb Ram Om Prakash Marketing Pvt Ltd Vs. Commissioner Of Income Tax & ORS

The Commissioner Of Income Tax Vs. Denso India Limited
September, 05th 2017
$~
*     IN THE HIGH COURT OF DELHI AT NEW DELHI
66-75
+                 ITA 371/2005

       THE COMMISSIONER OF INCOME TAX           ..... Appellant
                    Through: Mr. Raghvendra Singh with Mr. Ashok
                    Manchanda, Advocates.

                               versus

       DENSO INDIA LIMITED                        ..... Respondent
                     Through: Mr. Prakash Kumar, Advocate.

                                    With
+                              ITA 372/2005

       THE COMMISSIONER OF INCOME TAX           ..... Appellant
                    Through: Mr. Raghvendra Singh with Mr. Ashok
                    Manchanda, Advocates.

                               versus

       DENSO INDIA LIMITED                        ..... Respondent
                     Through: Mr. Prakash Kumar, Advocate.

                                    With
+                              ITA 373/2005

       THE COMMISSIONER OF INCOME TAX           ..... Appellant
                    Through: Mr. Raghvendra Singh with Mr. Ashok
                    Manchanda, Advocates.

                               versus

       DENSO INDIA LIMITED                        ..... Respondent
                     Through: Mr. Prakash Kumar, Advocate.




ITA 371/2005 & connected matters                          Page 1 of 15
                               With
+                              ITA 374/2005

       THE COMMISSIONER OF INCOME TAX           ..... Appellant
                    Through: Mr. Raghvendra Singh with Mr. Ashok
                    Manchanda, Advocates.

                               versus

       DENSO INDIA LIMITED                        ..... Respondent
                     Through: Mr. Prakash Kumar, Advocate.

                               With
+                              ITA 375/2005

       THE COMMISSIONER OF INCOME TAX           ..... Appellant
                    Through: Mr. Raghvendra Singh with Mr. Ashok
                    Manchanda, Advocates.

                               versus

       DENSO INDIA LIMITED                        ..... Respondent
                     Through: Mr. Prakash Kumar, Advocate.

                               With
+                              ITA 376/2005

       THE COMMISSIONER OF INCOME TAX           ..... Appellant
                    Through: Mr. Raghvendra Singh with Mr. Ashok
                    Manchanda, Advocates.

                               versus

       DENSO INDIA LIMITED                        ..... Respondent
                     Through: Mr. Prakash Kumar, Advocate.

                                    With
+                              ITA 377/2005




ITA 371/2005 & connected matters                          Page 2 of 15
       THE COMMISSIONER OF INCOME TAX           ..... Appellant
                    Through: Mr. Raghvendra Singh with Mr. Ashok
                    Manchanda, Advocates.

                               versus

       DENSO INDIA LIMITED                        ..... Respondent
                     Through: Mr. Prakash Kumar, Advocate.


                               With
+                              ITA 379/2005

       THE COMMISSIONER OF INCOME TAX           ..... Appellant
                    Through: Mr. Raghvendra Singh with Mr. Ashok
                    Manchanda, Advocates.

                               versus

       DENSO INDIA LIMITED                        ..... Respondent
                     Through: Mr. Prakash Kumar, Advocae.

                                    With
+                              ITA 380/2005

       THE COMMISSIONER OF INCOME TAX           ..... Appellant
                    Through: Mr. Raghvendra Singh with Mr. Ashok
                    Manchanda, Advocates.

                               versus

       DENSO INDIA LIMITED                        ..... Respondent
                     Through: Mr. Prakash Kumar, Advocate.

                               And
+                              ITA 381/2005




ITA 371/2005 & connected matters                          Page 3 of 15
       THE COMMISSIONER OF INCOME TAX           ..... Appellant
                    Through: Mr. Raghvendra Singh with Mr. Ashok
                    Manchanda, Advocates.

                               versus

       DENSO INDIA LIMITED                        ..... Respondent
                     Through: Mr. Prakash Kumar, Advocate.

       CORAM:
       JUSTICE S.MURALIDHAR
       JUSTICE PRATHIBA M. SINGH

                               ORDER
%                              31.08.2017
Dr. S. Muralidhar, J.
1. These are ten appeals by the Income Tax Department (`Department')
under Section 260A of the Income Tax Act, 1961 (`Act') directed against
the common order dated 2nd September 2004 passed by the Income Tax
Appellate Tribunal (`ITAT') in ITA Nos. 3233 to 3242/Del/2003 for the
Financial Years (`FYs') 1988-89 to 1997-98.

2. While admitting these appeals on 23rd August, 2006 this Court framed the
following question of law for consideration:
       "Whether the Income Tax Appellate Tribunal was correct in law in
       holding that the Commissioner of Income Tax (Appeals) had in fact
       reviewed its earlier order dated 29th January 2003 while exercising
       jurisdiction under Section 154 of the Income Tax Act, 1961, which
       only permits rectification of error apparent on the fact of the record?"

3. The background facts are that the Respondent-Assessee was incorporated
under the Companies Act, 1956. It has a manufacturing unit at Greater
Noida (Uttar Pradesh). It is an admitted position that M/s. Denso







ITA 371/2005 & connected matters                                   Page 4 of 15
Corporation, Japan had, during the period under consideration, deputed
technicians to work for the Assessee at its manufacturing unit. These,
expatriate technicians are paid salary in rupees by the Assessee apart from
the rent free accommodation. The salary paid was debited in the books of
the Assessee after deducting tax.

4. A survey was conducted in the premises of the Assessee on 14th
November 1998. According to the Department, the Assessee had paid
substantial part of the salary and allowances etc. to its expatriate employees
in Japan and had kept this amount out of the pale of taxation in India. It was
therefore alleged that the Assessee did not comply with Section 192 of the
Act under which there was an obligation to deduct tax at source. According
to the Department, a sum of Rs. 5,74,10,405 had been failed to be deducted
by the Assessee for the aforementioned AYs.


5. A show-cause notice (`SCN') dated 28th January 2000 was issued to the
Assessee. In response thereto, the Assessee by its letters dated 2nd February
and 8th February 2000 stated that after discussion with the Japanese
Chamber of Commerce and Industry, CBDT, CCIT and CIT-VI, the
Assessee had paid revised tax and interest under Section 201 (1) (a) of the
Act. The Assessee stated that it had no intention of concealing any income
or TDS. The Assessee stated that it had been advised that salary paid outside
India was not liable to tax in India. The Assessee accordingly submitted that
it was prevented by reasonable cause for not deducting tax at source on the
sum paid outside India.




ITA 371/2005 & connected matters                                  Page 5 of 15
6. The Assessing Officer (`AO') passed an order dated 19 th July 2000 under
Section 271 C of the Act holding that the Assessee had not been prevented
by any reasonable cause to comply with Section 192 of the Act and was,
therefore, liable to penalty in the sum of Rs. 5,74,10,405.

7. Aggrieved by the above order, the Assessee filed an appeal before the
Commissioner of Income Tax (Appeals) [`CIT (A)']. By an order dated 29 th
January 2003, the CIT (A), after referring to the decisions in the cases of
M/s. Subros Limited and M/s. Hyundai Engineering & Construction Co.
Ltd., held that "there is reason to hold the existence of reasonable cause in
this case." The CIT (A) further held that "the quantum of short deduction
has also undergone substantive change involving a variation of more than
Rs. 2 crores which would indicate that the quantum of default itself was not
known to the JCIT when the penalty was imposed." It was accordingly held
that no penalty under Section 271 C was warranted.

8. About three months thereafter, on 1st May 2003, the CIT (A) suo motu
passed an order under Section 154 of the Act. The opening lines of the said
order stated: "in this case action for rectification of mistakes in the appeal
order passed on 29th January 2003 was initiated under Section 154 of the
Act." The CIT (A) proceeded to observe that subsequent to the order passed
on 29th January 2003, eight appeals of the Assessee relating to FYs 1989-90
to 1992-93 and 1994-95 to 1997-98 were taken up for hearing on 8th April
2003. The Assessee did not attend the hearing but the AO who attended the
hearing was asked to bring all files relating to the case. The CIT (A)
proceeded to list out the facts revealed from the files inter alia to the effect




ITA 371/2005 & connected matters                                   Page 6 of 15
that the Assessee had not disclosed its tax liability under VDIS fully and
correctly; grossing up of tax was not correctly done and the statement of the
Managing Director recorded on 10th December 1998 was totally `evasive'.
In para 12 of its order, the CIT (A) set out in a tabular form the obvious
mistakes that had occurred when the earlier order dated 29th January 2003
was passed by the CIT (A). Inter alia it was noted that the case of the
Assessee was not similar to Marubeni Corporation or Mitusi & Co. The CIT
(A) therefore, felt it necessary to rectify the mistakes apparent from the
record. It was observed by the CIT (A) as under:
       "16. The findings given earlier would undergo complete change
       because the facts mentioned above show that this case did not qualify
       the first three tests laid down by the Delhi High Court in the case of
       Azadi Bachao Andolan (mentioned in para 5 above) and the facts of
       this case are not similar to the facts of the cases cited by the
       Appellant. These are two important points on which I had decided that
       the Appellant had a reasonable cause and imposition of penalty was
       not justified. Another important point in favour of the Appellant was
       that the shortfall in tax deduction had been varied by Rs. 2 crores
       approximately and now this also has been proved to be a mistake.
       Further, it is obvious that the penalty amount was quantified correctly
       on the basis of figures of short deduction of tax calculated by the
       company. These mistakes go to the root of the order and will change
       the entire basis for cancellation of penalty. The effect of rectifying the
       mistakes will be to uphold the order imposing the penalty by the JCIT
       and after incorporating the facts mentioned above I rectify my order
       of 29th January 2003 and confirm the penalty of Rs. 5,74,10,405
       levied.

       17. After noticing the mistakes from the records, I cannot restrain
       myself from commenting that the case was presented earlier in such a
       way as to show that the facts were entirely similar to the facts of
       Munjal Showa Limited, Fuji Bank Limited, Mitsui & Co., Subros
       Limited and Marubeni Corporation. It was only because of the later
       appeals filed in this case that I had the occasion to see the survey file



ITA 371/2005 & connected matters                                    Page 7 of 15
       of the AO which revealed the mistakes that had cropped up earlier."

9. Accordingly, the CIT (A) confirmed the penalty of Rs. 5,74,10,405 levied
by the AO.

10. The Assessee filed appeals being ITA Nos. 3233 to 3242/Del/2003
against the order passed by the CIT (A) on 1 st May 2003. Thereafter, the
Department filed appeals before the ITAT against the earlier order dated 29th
January 2003 of the CIT (A). These appeals were numbered as TDSA Nos.
4151 to 4159/Del/2004 for the Assessment Years (`AYs') 1989-90 to 1997-
98.

11. The ITAT, by the impugned order dated 2nd September 2004, allowed
the Assessee's appeals against the order dated 1st May 2003 of the CIT (A).
The ITAT held that the order of the CIT (A) was without jurisdiction. Since
the CIT (A) did not have the power to review its own orders, it cannot do so
indirectly. If aggrieved by the order dated 29th January 2003 of the CIT (A),
the right course was for the Department to adopt was to challenge it before
the ITAT. The CIT (A) could not possibly rehear the same appeal over and
over again.

12. The ITAT has in its impugned order dated 2nd September 2004
specifically noted that "the Department as informed by the learned DR
during the course of the hearing of the appeal, has already filed appeal
against the original order of the CIT (A)."


13. Against the said order dated 2nd September 2004 of the ITAT, the




ITA 371/2005 & connected matters                                 Page 8 of 15
Revenue filed these appeals which came up for hearing first on 8th July
2005. Interestingly, on 20th October 2005 Mr. C.S. Aggarwal, learned Senior
counsel appearing for the Assessee/Respondent in these appeals and
informed the Court that: `The Revenue has preferred an appeal against the
original order passed by the Commissioner deleting the penalty levied upon
the Assessee." The said appeal, according to Mr. Aggarwal, was coming up
for hearing before the ITAT on 3rd January 2006. In those circumstances,
the Court considered it appropriate to adjourn the hearing of these appeals
till such time the said appeal was disposed of by the ITAT.


14. What was perhaps not informed to this Court was that those appeals
were in fact disposed of by the ITAT on 13th May 2005 itself. By the said
order, the ITAT noted that after the survey was conducted, the Assessee
voluntarily filed revised its computation of tax and interest on 13th January
1999 without raising any dispute and without waiting for any demand or
penalty notice. The ITAT held that in view of the decisions of this Court in
Azadi Bachao Andolan (2001) 252 ITR 471 (Del)), and the decisions of the
ITAT in Mitsui & Co. 65 TTJ 1 and Fuji Bank Limited 121 Taxman 25 in
which the penalty under Section 271C had been deleted in similar
circumstances, there was no legal infirmity in the order of the CIT (A).
Consequently, the appeals of the Department dismissed.

15. The Department filed appeals being ITA Nos. 357 to 359 of 2006, 361 of
206, 364 to 366 of 2006, 368, 369 and 2006 in this Court against the order
dated 13th May 2005 of the ITAT. This Court by its order dated 24 th March
2006 referred to its orders in the case of Mitsui & Co. and observed in para 2




ITA 371/2005 & connected matters                                  Page 9 of 15
of the order, as under:
       "In the circumstances, therefore, and keeping in view the fact that the
       Tribunal and this Court have in similar other cases involving non-
       deduction of tax from the salaries paid to expatriate employees in
       countries outside India held that the failure to make the deduction at
       source was for a reasonable cause, we see no reason to interfere.
       Following the view taken by this Court in the cases mentioned above
       and the orders passed in ITA No. 355/2006 and connected matters
       decided on 22nd March 2006, these appeals fail and are accordingly
       dismissed."

16. For some reason, when the said appeals of the Department were heard by
this Court on 24th March 2006, the Court was not informed of the pendency
of the present appeals against the ITAT's order dated 2nd September 2004
although, as already noticed hereinabove, the vice-versa happened, viz., the
Court hearing these appeals was informed on 20 th October 2005 of the
appellate proceedings emanating of the order dated 29 th January 2003 of the
CIT (A).

17. When these appeals were thereafter heard on 23rd August 2006, this
Court too was not informed that the Department's appeals against the order
dated 13th May 2005 of the ITAT [which affirmed the order dated 29th
January 2003 of the CIT (A)] stood dismissed by this Court on 24th March
2006. Why the Department failed to do so is indeed a mystery.

18. The Department then carried the order dated 24th March 2006 passed by
this Court in appeal to the Supreme Court. The said appeals of the
Department were heard along with a batch of other appeals and were
decided by a common judgment in Commissioner of Income Tax v. Eli
Lilly and Co. (India) P. Ltd. (2009) 312 ITR 225 (SC). Learned counsel for



ITA 371/2005 & connected matters                                  Page 10 of 15
the Assessee has placed before the Court a copy of the aforementioned
judgment which shows that the appeal concerning the present Assessee was
CA No. 1634 of 2006. The case status available on the website of the
Supreme Court shows that the said appeal was disposed of on 25th March
2009.


19. The Supreme Court noted the issue involved in para 8 of its judgment as
under:
         "8. To complete the chronology of events, we may state that in some
         of the cases herein the Department has levied penalty under Section
         271C of the 1961 Act for failure to deduct tax under Section 192(1)
         from out of Home Salary paid outside India by the Head Office
         ("HO") to the expatriates deputed to the Branch Office(s) in India
         which penalty was set aside on the ground that the expatriates
         exercised dual employment and that there was no obligation on the
         Branch Office to deduct tax under Section 192(1) on the Home Salary
         paid by the HO outside India. It was further held that the said Home
         Salary paid by the HO was not on account of or on behalf of the
         Branch Office since no deduction was claimed for the salaries paid
         outside India in computing the income of the Employer and
         accordingly it was held that no penalty was leviable under Section
         271C of the 1961 Act. Against deletion of penalty under Section
         271C, the Department has come to this Court by way of these Civil
         Appeals."

20. While the issues concerning Section 201 (1) and Section 201 (1A) were
decided in favour of the Department, specific to the issue concerning penalty
under Section 271C of the Act, the Supreme Court held as under:
         "36. Section 271C inter alia states that if any person fails to deduct
         the whole or any part of the tax as required by the provisions of
         Chapter XVII-B then such person shall be liable to pay, by way of
         penalty, a sum equal to the amount of tax which such person failed to
         deduct. In these cases we are concerned with Section 271C(1)(a).






ITA 371/2005 & connected matters                                   Page 11 of 15
       Thus Section 271C (1)(a) makes it clear that the penalty leviable shall
       be equal to the amount of tax which such person failed to deduct. We
       cannot hold this provision to be mandatory or compensatory or
       automatic because under Section 273B Parliament has enacted that
       penalty shall not be imposed in cases falling thereunder. Section 271C
       falls in the category of such cases. Section 273B states that
       notwithstanding anything contained in Section 271C, no penalty shall
       be imposed on the person or the Assessee for failure to deduct tax at
       source if such person or the Assessee proves that there was a
       reasonable cause for the said failure. Therefore, the liability to levy of
       penalty can be fastened only on the person who do not have good and
       sufficient reason for not deducting tax at source. Only those persons
       will be liable to penalty who do not have good and sufficient reason
       for not deducting the tax. The burden, of course, is on the person to
       prove such good and sufficient reason. In each of the 104 cases before
       us, we find that non-deduction of tax at source took place on account
       of controversial addition. The concept of aggregation or consolidation
       of the entire income chargeable under the head "Salaries" being
       exigible to deduction of tax at source under Section 192 was a nascent
       issue. It has not be considered by this Court before. Further, in most
       of these cases, the tax- deductor-Assessee has not claimed deduction
       under Section 40(a)(iii) in computation of its business income. This is
       one more reason for not imposing penalty under Section 271C
       because by not claiming deduction under Section 40(a)(iii), in some
       cases, higher corporate tax has been paid to the extent of Rs. 906.52
       lacs (see Civil Appeal No. 1778/06 entitled CIT v. The Bank of Tokyo-
       Mitsubishi Ltd). In some of the cases, it is undisputed that each of the
       expatriate employees have paid directly the taxes due on the foreign
       salary by way of advance tax/self-assessment tax. The tax-deductor-
       Assessee was under a genuine and bona fide belief that it was not
       under any obligation to deduct tax at source from the home salary
       paid by the foreign company/HO and, consequently, we are of the
       view that in none of the 104 cases penalty was leviable under Section
       271C as the respondent in each case has discharged its burden of
       showing reasonable cause for failure to deduct tax at source."

21. The conclusions reached by the Supreme Court as regards the above
issue is to be found in para 39 of the said judgment, which reads as under:



ITA 371/2005 & connected matters                                    Page 12 of 15
       "39. For the reasons mentioned hereinabove, however, no penalty
       proceedings under Section 271C shall be taken in any of these cases
       as the issue involved was a nascent issue. Accordingly, we quash the
       penalty proceedings under Section 271C."

22. Specific to 104 cases which were before it, including that of the
Respondent-Assessee, the Supreme Court was of the view that in "none of
the 104 cases penalty was leviable under Section 271C as the Respondent in
each case has discharged its burden of showing reasonable cause for failure
to deduct tax at source." The resultant position as far as the order dated 29th
January 2003 of the CIT (A) reversing the penalty order of the AO is
concerned, it stood affirmed by the ITAT by its order dated 13 th May 2005,
then this Court by an order dated 24th March 2006 and finally by the
Supreme Court by the judgment dated 25th March 2009.


23. This Court is unable to understand what prevented the Department from
bringing the above developments, specific to the case of the present
Assessee, to the notice of the Supreme Court before it delivered the above
judgement dated 25th March 2009. It will be recalled that the Department did
not point out to this Court the additional facts taken note of by the CIT (A)
(while exercising suo motu powers of review) when it dismissed the
Department's appeals on 24th March 2006.

24. Mr. Raghvendra Singh, learned counsel for the Department, suggested
that the proceedings emanating from the order dated 1st May 2003 of the
CIT (A) was separate. Those facts, according to him, were not present
before the ITAT which heard the Department's appeals against the order
dated 29th January 2003 of the CIT (A). He submitted that in any event since



ITA 371/2005 & connected matters                                  Page 13 of 15
these appeals have been admitted and the question framed, they have to be
heard and disposed of on merits.

25. The Court fails to understand how, after the Supreme Court has by its
judgment dated 25th March 2009 categorically held on facts that the
Respondent-Assessee had discharged the burden of showing reasonable
cause for the failure to deduct TDS, this Court can possibly pass an order in
the present appeals which might have the effect of contradicting the
aforementioned judgment of the Supreme Court.


26. It is strange that the Department allowed the proceedings to continue on
two parallel tracks without making an effort, even before the ITAT, to have
the two appeals ­ i.e. the Department's appeals against the CIT (A)'s order
dated 29th January 2003 and the Assessee's appeals against the CIT (A)'s
order dated 1st May 2003 - heard together. This has to be understood in the
context of the fact that by the time the ITAT heard the Assessee's appeals
against the CIT (A)'s order dated 1st May 2003, it had already before it the
Department's appeals against the order dated 29th January 2003. When the
Assessee's appeals were taken up for hearing, the Department should have
pointed out to the ITAT that its appeals against the order dated 29th January
2003 were pending.


27. Again, when this Court was on 24th March 2006 hearing the
Department's appeals against the order dated 13th May 2005 of the ITAT, it
was not informed that the present appeals against the ITAT's order dated 2nd
September 2004 which had been filed by the Department on 31st January




ITA 371/2005 & connected matters                                 Page 14 of 15
2005 itself. The Department ought to have requested this Court to hear both
sets of appeals together.


28. In light of the fact that the Supreme Court has by its judgment dated 25 th
March 2009 held on merits that the Respondent-Assessee had discharged the
burden of showing reasonable cause for the failure to deduct TDS, the Court
is not persuaded to entertain the present appeals. The question that has been
framed does not require to be answered for the simple reason that the
decision of this Court cannot possibly be contrary to what has been held by
the Supreme Court on merits on the question of the liability of the Assessee
to pay penalty under Section 271C of the Act.


29. For the aforesaid reasons, the Court declines to answer the question
framed. The appeals are dismissed with no order as to costs.




                                                      S. MURALIDHAR, J.



                                                 PRATHIBA M. SINGH, J.
AUGUST 31, 2017
Rm




ITA 371/2005 & connected matters                                  Page 15 of 15

 
 
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