TaxTMI 
TaxTMI 
2014 (10) TMI 900
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.... as against capital expenses. 3. Whether on the facts and circumstances of the case, the Ld. CIT(A)Panaji, has erred in deleting addition of Rs. 9,73,844/- made by the AOon account of Salvage Wreck Removal Expenses. 4. The Ld. CIT(A), Panaji has erred in deleting addition of Rs. 35,89,64,088/- relating to capital expenditure incurred on ship renovation viz M V Sunrise, made by the AO ignoring the decisions of the supreme court in the case of CIT v/s Saravana Spinning Mills Pvt. Ltd 293 ITR 201 and Ballimal Naval Kishore V/s. CIT (1997) 244 ITR 414, Modi Spinning & Weaving Mills Co. Ltd V/s. CIT (Del) 200 ITR 544). Current repairs does not include capital expenditure u/s. 31. 5. The Ld. CIT(A), Panaji has erred in deleting addition of Rs. 15,25,16,576/- made by the AO towards unaccounted / excess stock by ignoring the strong evidence collected by the AO in the shape of letter dated 06/12/2010 given by the Directorate of Mines and Geology, Government of Goa which confirms the production or the extraction of ore in the mines of the assessee at 7,833MT only during the period relevant to A.Y. 2008-09." 2.1. Wherein the following grounds are raised by the as....
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....curred on earning this dividend income. After considering the reply the Assessing Officer has calculated the disallowance. The Assessing Officer has also verified and informed that the assessee has maintained as diverse equity portfolio and has invested in 3 different companies and mutual funds the investments in these companies and funds at the beginning and close of the period relevant to this assessment year is as under: The Assessing Officer found that assessee was moved funds from one scheme to another possibly with a view to get better returns. Therefore, the Assessing Officer has relied upon the various decisions and he has calculated the disallowance u/s. 14A r.w.s. 8D, a sum of Rs. 32,40,027/- ,. The assessee has given the calculation of disallowance u/s. 8D but Assessing Officer was of the view that this calculation of the assessee is not as per law, therefore, he disallowed a sum of Rs. 32,40,027/- 3.2. The matter carried to CIT(A) and CIT(A) has dismissed the appeal of the assessee. 3.3. During the course of hearing, we find that the assessee has given the calculation of his disallowance u/s. 14A r.w.Rule 8D which read as under: 1 Amount of expenditure di....
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....al of the Assessee is allowed statistical purpose. 4. Ground NO. 2 which read as under:- "2. The CIT(A) has erred in treating contribution of Rs. 13,854,167/-, to Goa Infrastructure Development Company Limited, a Government undertaking, towards construction of Usgao Bridge which is essential for smooth and efficient running of the business of the assessee, as a capital expenditure." 4.1. The short facts of this ground is that the assessee company has debited a sum of Rs. 1,38,54,167/- as contribution to Goa Infrastructure Development Co. Ltd., for construction of Usgao Bridge. It has been submitted that Govt of Goa has asked to mines at Usgao area construction the bridge as the bridge was used by them for transportation of minerals ores. The old bridge was claimed to have been damaged because of the transportation undertaken by the mine owners. Since it was not possible for the mine owners to operate their mines and to transport ores, all the mine owners of the area who used this bridge agreed for construction of the bridge. The assessee has contributed a sum of Rs. 1,38,54,167/- and claimed as a business expenditure as a revenue expenditure. 4.2. The matter carri....
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.... and the ownership of the same was not with the assessee. Deduction for the same was claimed as revenue expenditure. The Tribunal relied on the Supreme Court judgment of Empire Jute co. Ltd. V. CIT[1980] 124 ITR 1 (SC), wherein it was held that the inference, whether a particular expenditure was in the nature of capital expenditure or revenue expenditure was dependent on the facts of thecase.A lump sum payments or enduring benefit is not conclusive test. The Supreme Court had further held that where the payment for securing an enduring advantage is in the revenue filed it would be revenue in nature. Where the expenditure was for operation and the working of an existing profit-making apparatus, it could only be revenue in nature. It is only where the expenditure was related to any addition or augmentation of the profit-making apparatus, the same would be capital in nature. Respectfully following the same, we allow the claim. This ground of Appeal is allowed. ITA No. 361/PNJ/2013 for A.Y.2008-09 Ground No.1. General in nature 5. Ground No.2 of the department's appeal which read as under:- "2. Whether on the facts and circumstances of the case, the Ld. CIT(A)Panaji, has....
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....account of facility assessee dreading operation or enabling maintenances and conduct of the assessee's business more preoperatively while living the fix capital on tax. Replacement of sand is revenue expenditure. In this case the assessee had incurred the expenses for preserving and maintaining already existing assets and does not bring a new assets or does not the assessee give on deferent advantage cannot be treated as capital expenses. In the case of CIT Vs. Hotel Control Pvt. Ltd. [2004] 265 ITR 109 (Uttaranchal), it was found admissible on the ground that the hotel situated at Mussorie had required such heavy expenditure as necessitated by climatic conditions. The issue had arisen because the assessee has treated it as deferred revenue expenditure prompting the Assessing Officer to treat it as a capital expenditure. Renovation was conceded in providing flush system for latrines, replacing tiled roof by cement roof, construction of a water tank, replacement of concrete floor by Kotaa stones and repairs to the furniture. Though the decision was rendered in the context of renovation necessitated by climatic conditions, the position should not be different, even where it is prompt....
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....herein it is held that in the case of salvaging asset if the expenditure or nature of transaction is such as to be regarded as one in the revenue field, it cannot be treated as capital, merely because such expenditure is incurred for the purpose of salvaging the capital. We find that the CIT(A) is justified in his treating this expenditure as revenue expenditure and our interference is not required. In the result, revenue appeal is dismissed on this ground. A.Y.2007-08 treated as a revenue expenditure. 7. Ground No.4This ground relates to deleting the addition of Rs. 35,89,64,088/- as capital expenditure incurred on ship renovation viz M V Sunrise.The assessee company has incurred the following expenditure which read as under:- Sr. No. Particulars Amount (US$) Remarks 1 Towards the payment to cosco (Nantong) Shipyard Co. Ltd for dry-dock charges and related charges 43,98,000.00 These are all the charges of shipyard which include the repairs and servicing of the ship. These repairs are mainly the replacement of steel plates and other parts. The hull of the ship is of steel plates. Since the ship is always in water, the hull gets corroded and hence the majo....
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....d a double reversible diesel engine of 1973 make. Certificate of class issued by Indian Register of Shipping on 17.02.2006 vide certificate no. 06047 as per which subsequent to survey carried out in March/September 2005, the ship was certified for transshipment services in fair weather within 12 nautical miles off ports on west coast of India and for transit between them in ballast till 29.03.2010. Certificate No. COL10P034 dated: 13.09.2010 issued by Indian Register of Shipping carrying following particulars: Particulars of Ship Name of Ship SUNRISE Distinctive number or letters 2769/VVRO Port of Registry Mumbai Length (L) as defined in article 2(8)(metres) 215.42 Gross Tonnage 34920 IMO Number 7352335 Freeboard assigned as *A new ship Type of ship *Type B vii. The aforesaid three certificates issued by Certificate of Indian Registry/Indian Register of Shipping on various dates reveal the Following: The ship M.V. Sunrise was manufactured in 1974 and had an engine of 1973 vintage. The ship was therefore very old and its designated life was due to expire shortly. The ship M.V. Sunrise had ....
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....explanation to section 31 that was inserted w.e.f. 1.04.2004 specifically excludes any expenditure in the nature of capital from current repairs. The Assessing Officer was of the view that the expenditure on dry docking was not an annual affairs and Most of the parts of the ship were overhauled or renewed during the dry docking and hence the asset was restored. It was replaced major parts of the body of the asset. Therefore, the Assessing Officer was of the view that this is not a routine expenditure towards running/operation of the aforesaid vessel but was in the nature of structural remodelling which tantamount to creation of the new capital asset that would give benefit of an enduring nature to the assessee company. Therefore, he treated this as a capital expenditure and the Assessing Officer has allowed depreciation from A.Y. 2010-11. 7.1. Matter carried to CIT (A). 7.2. CIT(A) verified the detail expenditure and he categorized following expenditure can never be treated as capital expenditure which read as under: Sr. No. Particulars Amount (US$) Remarks 1 Towards the payment to Cosco (Nantong) Shipyard Co. Ltd for dry-dock charges and related charges ....
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....ticular expenditure is revenue or capital in nature. 1St question arises, whether a new asset has come into existence. The answer is in the negative. Next question is, whether the character of the asset is changed or the capacity of the vessel has increased. Again the answer is in negative. In fact, in this case, the appellant had to incur expenditure in order to keep the vessel sea-worthy and just because the expenditure is large, it can be said that the expenditure incurred is capital in nature. In this case old engine has not been replaced by a new engine, increasing the capacity of the vessel. Taking a birds eye view of the complete facts of the case, in my opinion, the repairs expenses was required to keep the vessel sea-worthy and should be treated as current repairs and be allowed as revenue expenditure. The A.O. is directed to delete the addition amounting to Rs. 35,89,64,088/- made on this account and this Ground of appeal of the appellant is allowed accordingly." 7.3. The learned DR submitted that the Assessee, vide his paper book submitted in last hearing on 14.07.2014, has said that the expenses incurred for dry docking are revenue in nature. Assessee says it is to b....
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.... expenses like travelling, stationery, Telephone etc incurred at China and Singapore 5,35,524.91 These are related expenses 7 Towards our technical consultancy, supervision during repairs and providing funds being 5.25% of the full amount 4,45,380.00 These are the fees. Total 89,25,812.80 (United States Dollar Eight Million Nine Hundred Twenty Eight Thousand Eight Hundred Twelve and Cents Eighty only) These expenditure can be summarized in Indian currency as under:- Sr. No Particulars Amount in Rs. 1 Cosco Nantong Shipyard Co. Ltd for dry dock and related expenses 176,812,310 5.25% consultancy service 9,282,647 2 For supply of Bunker/Fuel at Singapore and china 67,885,695 5.25% consultancy service 3,563,999 3 Port disbursement charges China Ocean Shipping Agency, Nantong 1,660.728 5.25% consultancy service 87,188 4 Towards supply (purchase) of spares and consumables stores 71,400,912 5.25% consultancy service 3,748,548 5 Towards supply of provisions for ships crew during their stay in china and Singapore 1,....
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....ng on various dates reveal the Following: The ship M.V. Sunrise was manufactured in 1974 and had an engine of 1973 vintage. The ship was therefore very old and its designated life was due to expire shortly. The ship M.V. Sunrise had a valid certificate for transshipment services till 29.03.2010. Thus, there was no need to carry out dry-docking restoration in June 2007 merely to obtain a seaworthiness certificate. The assessee's contention that dry-docking was necessary for obtaining the aforesaid seaworthiness certificate is therefore not supported by facts on record. After the dry-docking restoration, the ship M.V Sunrise was assigned as a new ship albeit carrying the old registration. This shows that dry-docking rejuvenatedrestored the old ship as a new asset." After verifying this expenditure the Assessing Officer has treated this expenditure as capital expenditure but CIT(A) has also verified the detail expenditure and he categorized following expenditure can never be treated as capital expenditure which read as under: Sr. No. Particulars Amount (US$) Remarks 1 Towards the payment to Cosco (Nantong) Shipyard Co. Ltd for dry-dock charges and related charges ....
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....reased. The matter was remanded to arrive at such finding. In CIT vs. Shri Hari Mills Pvt. Ltd... 237 ITR 188 (Mad). Replacement of worn out machinery parts of machinery, such replacement, renewals and repairs were to keep business going withou8t breakdown of machinery, machineries were not replaced wholly nor new machineries were added, such expenditure cannot be treated as capital expenditure. In CIT Vs. Shri. Raani Laakshmi Ginning Spinning and Weaving Mills Ltd.. 256 ITR 592 (Mad). Replacement of old and worn out parts in machinery, finding that without replacing all those parts, production could not be carried on smoothly, held that no error in order of ITAT allowing deduction of the expenditure as revenue expenditure. In CIT vs Cooperative Sugar Ltd.239 ITR 908 (Ker). The machinery was replaced. It was held that expenditure incurred on replacement of machinery was revenue expenditure. In CIT vs Asher Textiles Ltd., 240 ITR 483. The old ceiling was replaced. It was held that expenditure on replacement of old ceiling made of hardboard set on wooden frames with thermostat wood insulation board set in aluminiumframesconstitute revenue expenditure. After the amendment of section 3....
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....stock of iron ore in this mine for this year was asunder: Opening Stock at Kali Mines - 64,135 MT Closing Stock at Kali Mines - 1,15,000 MT Thus, out of 2,74,985 MT claimed to have been mined by theassessee during the year, the assessee sold/otherwise moved2,24,030 MT of the iron ore. Rule 64-B of the MineralConcession Rules 1960 that deals with charging of royalty incase of minerals subjected to processing provide as under: 64-B. Charging of Royalty in case of minerals subjected to processing: - 1) In case processing of run-of-mine mineral is carried out within the leased area, then, royalty shall be chargeable on the processed mineral removed from the leased area. ii) In the case run-of-mine mineral is removed from the leased area to a processing plant which is located outside the leased area, then, royalty shall be chargeable on the unprocessed run-of mine mineral and not on the processed product. Iron-ore taken out from mines is subjected to processing to make it marketable through beneficiation. Consequently, provisions of these Rules are squarely applicable. As per this, the assessee should have paid royalty on at least 2,24,030....
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....,534 Closing Stock: 12,09,267 MT Total: 48,31,340 MT Total: 51,06,325 MT Excess: 2,74,985 MT The aforesaid shows that the assessee had sold/possessed as closing stock an excess amount of 2,74,985 T of iron ore vis-avis the amount of iron ore possessed by him as opening stock and that purchased by him during the year. This excess amount of iron ore totalling 2,74,985 MT, the assessee is claiming to have excavated from its mines. However, as per records, the assessee has mined only 75,833 MT of iron oreduring the year. Hence the assessee is in possession of excess stock of iron ore of 1,99,152 MT during this year. The assessee was accordingly asked to clarify as to why this quantity of 1,99,152 MT of iron ore claimed to have mined from Kelim mines but not actually mined as shown by the available records, be treated as unexplained stock. In its reply, the assessee has taken the stand that the actual amount of iron ore extracted from Kelim mines during the year was 2,74,985 MT, however royalty was paid only on 75,833 MT of iron ore as the remaining ore was of a view low grade on which no royalty was considered as payable. The explanation of the ass....
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....s. Records show that the actual amount of iron ore mined by the assessee is 75,833 MT. In the case of Jai Sharda Rice Mills v. ITO (1991) 36 lTD 254, 258, it was held that the figure of stock checked and verified by other Government authorities should be preferred. In Century Foams (P). Ltd. v. CIT [1994] 210 ITR 625 (All.), it was held that if there was actual discrepancy in the stocks hypothecated to the bank and that shown in the accounts, for which the assessee failed to explain by. any acceptable explanation or material, no exception could be taken to the addition made by the authorities. Similar view was also adopted in the case of Kaila Sweet Supplier v. CIT [1998] 100 Taxman 59 (All.), where it was held that addition on account of difference between value of stocks declared to the bank and the value recorded in the assessee's books can validly bebrought to tax, if the information furnished by the bank contained not only the items of stock but also their quantity and the assessee did not discharge the burden cast on him to prove that the apparent was not real. In the instant case, the detailed figure of iron ore mined made available to the, Directorate of Mines, Governmen....
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....d. 400 United Trading. Buyer-DBB 6 - 52 Avg. Rate for purchase from Balanji Mines and Minerals Pvt. Ltd. 520 Salgaocar Mining Industries P. Ltd. 7 - 52 Avg. Rate for purchase from R. Praveen Chandra. 250 Salgaocar Mining Industries P. Ltd. 8 - 52 Avg. Rate for purchase from Balaji Produce Co. 192.5 Salgaocar Mining Industries P. Ltd. 9 - 52 Avg. Rate for calibrated purchase from Salitho Ores P. Ltd. 150 Salgaocar Mining Industries P. Ltd. 1048.06 16082.5 Average Average rate 765.83 8.1. The matter carried to CIT(A) and CIT(A) has deleted the addition by observing as under: "7.4. I have gone through the assessment order and the arguments of the appellant. In this case, the assessee own mine and carries out extraction of iron ore. Apart from own extraction, the assessee also purchases iron ore from the market. On comparing various figures provided by the assessee, the A.O reached a conclusion that the assessee was in possession of 2,74,989 MT of unaccounted stock as under: Operating stock 7,18,806 &nbs....
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....Assessee claims that the royalty was paid on that on 08.10.2010. However, it is not true since, - There is no evidence that assessee paid royalty for the same iron ore only - Rule 64-B of the Mineral concession rules 1960 says that royalty is chargeable on the processed mineral removed from the leased area - Director of Mines, Govt of Goa vide his letter dated 16,12.2010 said the production of assessee for FY 2007-07 was only 78,883MT and paid royalty on the same - There were no primary documents to show how much ore was mined during FY 2007-08 - Assessee paid the royalty on supposed excess ore only after assessment proceedings started, ie. in Oct 2010. - Also, assessee says 1,991,152MT of ore was of low quality. But assessee has never sold any ore of such quality. (Assessee always sold 57% or more quality ore) So assessee contradicts himself when he says sold iron ore was of high quality but the mined ones were of very low quality. It is obvious that assessee sells iron ore outside the books and without primary documents, and only when assessment started, he paid some royalty and came with this explanation for the exce....
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....xpenditure towards the earning of the income under Rule 14A r.w. Rule 8D and assessee has submitted before CIT(A) which read as under: 1. Amount of expenditure directly relating to Dividend Income 0 2. The amount of interest which is not directly attributable to any particular income or Recent Formula AxB/C A=Amount of Interest other than interest included in (1) B=The average value of investment on which dividend earned C=Average total assets as appearing in B/Sheet at the first day and last day Here in the case of appellant A is Nil Because the interest paid were as under: On Fixed loans for purchase of assets.. Rs. 3,54,46,955 On Packing Credit... Rs. 1,91,95,204 On charter Hire/Hire Purchase Rs. 6,101987 Rs. 6,07,44,146 All these interests paid were directly attributable to the income from Sale of Ore, Transhipper Receipts, Hire Receipts Only. The Rule 8D talks about the interest which is not directly attributable to any particular income or receipts, herein our case interests paid were....
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....re. 1. (b). The assessee's Authorized Representative vide reply dated Nil, it is submitted that the expenditure of Rs. 48,60,08,180/- consists of maintenance and dry docking expenses for M.V. Sunrise. It was further states that all these expense were necessary for operating and maintaining the vessel in good working condition as well as to follow the norms laid down by the government regulatory bodies which have to be complied with, It was also stated that these expenses have to beincurred every year. (c).i. Details furnished by the assessee company have been considered. MN. Sunrise was purchased by the assessee company in 1998. The expenditure incurred by the assessee company during the last financial year on repairs and dry- docking of M.V. Sunrise is as under: Assessment year Amount of expenditure (Rs.) 2007-08 Nil- on dry-docking 47,87,518/- on other repairs 2008-09 35,89,64,088/-on dry-docking 11,70,335/- on other repairs 2009-10 48,60,08,180/- on dry-docking (Annual repair of ship) 38,10,277/- on other repairs The above table belies the contention of the assessee that dry-docking expenditure on M.V. Sunrise expenditure has to be i....
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....st of the part of the ship were overhauld or renewed during the dry-docking and hence the asset restored. * It replaced major part of the body of the asset. * It was not essential for continued running of the asset during the year. * It gave rise to an enduring benefit in terms of extended life of the asset to the assessee. The expenditure is therefore clearly in the nature of a capital expenditure. In CIT v. Nenoth Oil Mills Ltd. (Ker) 140 ITR 173, it was held that where in a fishing boat expenditure was incurred in fitting new engine but there was no finding that engine needed repairs or replacements and the renewal resulted in an enduring advantages, hence the expenditure could not be held revenue in nature. (c) iv, The aforesaid discussion shows that the expenditure of Rs. 48,60,08,180/- incurred on transformation of vessel M.V. Sunrise was not of the nature of routine and current repairs but was of the nature of structural modification of the ship with a view to enhancing its life. The structural modification was conducted by the assessee on the ship during the assessment year in order to enhance its life that would give a benefit of enduring natu....
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....t from the earlier contention that these were repairs of a routine nature, also mentioned that the loading capacity of the ship did not change as a result of these repairs. The comparative figures of the income from Transshipper are under: Asst Year Amounts in Rs. 2007-08 7,83,49,700 2008-09 1,46,93,500 2009-10 0(SELF USE) 2010-11 9,27,53,430 Thus, due to dry-docking, the income of the assessee from of MN. Sunrise had increased due to the restoration done during the dry-docking. As regards to other submissions made by the assessee that dry-docking was essential to maintain its sea worthiness. (c).vii. To determine whether an expenditure is revenue or capital in nature, certain broad tests have been laid down and the test suggested by Viscount Cave K.C. in Atherton V British Insulated and Heisby Cables Ltd. (1925) 10 TC 155 (HL) have been largely accepted. The Hon'ble Supreme Court in Assam Bengal Cement Co Ltd. v Commissioner of Income Tax (1955) 27 ITR 34 (SC); Sitalpur Sugar Works Ltd v CIT (1963) 49 ITR 160 and a number of other decisions has adopted the test as laid down in Atherton's case, "When expenditure is made....with view ....
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.... * The extended renovation that is in the nature of restoration has resulted in adding life to M. V. Sunrise, regenerated its functioning and increased its performance capacity. * Performance of the vessel also increased as a result of dry-dolcking as revealed by the increased revenue earned after the dry-docking. The expenditure is in the nature of a capital expenditure and will need to be treated as such, Accordingly, the expenditure of Rs. 48,60,08,180/- incurred by the assessee on the vessel M. V. Sunrise is disallowed as being capital in nature. Since the ship has been released from dry-docking on 30.09.2008 the depreciation for this year in this respect would allowed only to the extent of 50% of allowable depreciation i.e. 10%. Hence, the total addition on this count is Rs. 48,60,08,180/-. However the depreciation allowable would be Rs. 4,86,00,818/- on this count". 11.1. The matter carried toCIT(A) and CIT(A) has allowed the claim by observing as under:- "6.3. I have gone through the assessment order and the contentions of the appellant. The A.O. has not doubted the genuineness of these expenses, but his main contention is that by spending suc....
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....ll paid. 999 Equity Shares of Leela estate 99,900 99,900 Dev & Inv Co Pvt. Ltd. of the face value of Rs. 100/- each full paid. 501 Equity Shares of Audi Constructions Pvt. Ltd. of the face value of Rs. 100/ each full paid. B) In other Companies 1,80,000 Equity Shares of Damodar Bulk Carriers Pvt. Ltd. of the face value of Rs. 10/- each full paid. 10,85,724 Less: Provision for Diminution in Investments 10,85,724 Less: Provision for Diminution in Investments 10,85,724 50,100 10,85,724 (10,85,724) 500 Equity Shares of Nilhat Shipping 5,000 5,000 Co. Pvt. Ltd. of the face value of Rs. 10/- each full paid 500 Equity Shares of Jayaraj Estate 50,000 50,000 Development and Investment Co. Pvt. Ltd. of the face value of Rs.100/- each full paid. 29,000 Equity Shares of Bevit 2,89,500 289,500 Pharmaceuticals Pvt. Ltd. of the face value of Rs.10/- each full paid up. 6,50,000 Equity Shares of Fmam 65,00,000 65,00,000 Document 3 Airtime Pvt. Ltd. of the face value of Rs.10/- each full paid up. 7,50,000 Equity Shares of Millenium Deccan Broadcast Pvt. Ltd. of the face value ....
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....,239/- Nay 26.92 for 77,089.115 units) Fund ICICI Prudential Infrastructure JM Basic Fund (Market value 25,00,000 Rs.19,07,363/- Nav @ Rs. 26.,4211 for 72,190.907 units) ASK Portfolio (Market value 5,00,00,000 Rs.4,30,28,964/-) Total 15,74,91,905 22,19,41,805 Document 5 (i) Amount of expenditure directly relating to income which does not form part of total income (ii) in a case where the assessee has incurred expenditure by way of interest during the previous year which is not directly attributable to any' particular income or receipt, an amount computed in accordance with the following formula, namely:- [AxB]/C = Rs. [A]x Rs. —[B] = Rs. [C] .. NIL A Amount of expenditure by way of interest other than the amount of interest included in clause (i) incurred [A]=Rs.6,07,44,1467- during the previous year Document 6 B. The average of value of investment, income from which does not or shall not form part of the total income, as appearing in the balance sheet of the assessee, on the first day and the last day of the previous year: Opening Investment Closing Investme....