TaxTMI 
TaxTMI 
2019 (4) TMI 1215
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....allenging the withdrawal of exemption granted u/s 12AA of the Act. 3. Briefly stated, the facts of the case are that the assessee society is engaged in providing educational services through 19 educational institutes at Jaipur, Ajmer and Mumbai under the umbrella of St. Wilfred group of colleges. The ld. Pr. CIT referring to the objects of the assessee society and in view of various evidences in possession of the Department stated that the assessee is not working as per the objects for which registration was initially granted and the case of the assessee falls U/s 12AA(3) and 12AA(4) of the Act. These issues relate to diversion of fund of the assessee society for personal purposes, non-genuine scholarship expenses and addition to fixed assets in view of the payments made to Rajasthan Housing Board in contravention of Section 11(5) read with Section 13(1)(c) of the Act. In light of the discussion made in his order, the ld. Pr. CIT has held that the activities of the assessee society are not genuine and are not being carried out in accordance with the objectives of the assessee society and the registration of the assessee society U/s 12AA(1)(b)(i) was cancelled by invoking the pro....
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....any corresponding entry either in the books of the assessee society or in the books of the bank. As per ld Pr CIT, this clearly implies that the assessee indeed collected fees in old denomination notes illegally with an intention to get it exchanged by routing it through the Integral Urban Cooperative Bank, another concern where the management of St. Wilfred Education Society had effective control. Not recording of the cash receipt in its books of accounts clearly shows that the funds were being diverted for personal purposes and therefore the activities of the assessee are not genuine. 7. The ld. Pr. CIT further stated that serious discrepancies were also detected in the daily record of denomination of Rs. 500 /Rs.1000 notes maintained by the Integral Bank. One loose paper found and seized from the chamber of Shri Harish Gupta, GM of the Bank containing the actual record of cash position of the bank on 30.11.2016, which did not match with the actual breakup kept on record by the Bank in an electronic /soft form. It was evident from the hand written loose paper that the total cash balance shown in the hand written paper tallies with the total cash balance, shown in the daily cas....
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.... on 10.12.2018 wherein it has contended that the source of the cash found in the almirah in clearing house room of Integral Bank is undisputedly from fees collected from students of the assessee society, a fact which is supported by statements recorded from various persons during the survey / search action. Therefore, it was submitted that there is no basis with the Department for doubting the source of the cash found and they have themselves admitted that the source of the cash found was fee collected from students. Regarding the issue as to why the cash was not officially deposited by the bank, it was submitted that it is for the bank to explain the same and not the assessee. In relation to the fact that there are certain new notes which are in new series and which could not have been given by students as fees, the assessee contends that whatever money was sent by the assessee from the college i.e. Rs. 1,56,59,500/-, the same was duly accounted for in the books of the assessee society. It is for the bank to explain wherefrom the new notes came. Regarding the allegation that the diversion was done to benefit the Trustees (Badaya family), it was submitted by the assessee society th....
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....act clearly shows that the books of accounts of the assessee were manipulated for the benefit of the Badaya family as fees allegedly collected from students in old denomination was nowhere recorded in books of the assessee. Hence, these fees were free to be used by the Badaya family for their personal benefit. In case, fees were recorded in the books, then it would have been ensured that these receipts would have been used solely for the purposes for which the assessee society was established and in order to enjoy the funds for their personal benefit, the Badaya family did not record the fees received in the books of accounts of the assessee. It was finally held by the ld. Pr.CIT that the money found during search/survey was not recorded in the books of the Integral Bank and neither was it deposited in the bank account of the assessee. Therefore, this money was lying unaccounted and the promoters of the assessee were free to use this money as they deemed fit. The said money was diverted from the charitable education purposes and therefore the activities of the assessee society are not genuine. 10. The ld CIT DR has heavily relied on the aforesaid findings of the ld Pr.CIT. and s....
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....Each is operating legally in different fields. Therefore, if there was any discrepancy or illegality in the cash held, or, if the cash remained unexplained, then the Bank should have been questioned thereon, and action should have been taken against the Bank, and not the Appellant Society. This was very clearly pointed out in the reply to the show-cause notice submitted to the respondent. A copy of the reply filed before the PCIT (Central), Jaipur, in response to the show-cause notice dated 22.11.2018 is enclosed and marked as Annexure A/1. 14. It was further submitted by the ld AR that surprisingly, no discrepancy has been pointed out in the assessment order of the Integral Urban Co-operative Bank Ltd. passed recently U/S 143(3) r/w 153B(1)(b) on 28.12.2018 for A.Y 2017-18, the assessment year pertaining to previous year in which search was conducted. A copy of the assessment order for the A.Y. 2017-18 is enclosed and marked as Annexure A/2. In view of this fact, there is no reason to penalise the Appellant Society by cancelling its registration. 15. It was further submitted by the ld AR that in his order, the Respondent states that the Appellant Society has trustees which a....
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.... iii) Statement of Shri Vikram Singh, Cashier, Integral Urban Co-operative Bank Ltd. dated 10.12.2016 - reply to question no. 14 & 21. Thus, all contemporaneous statements confirmed that the cash of Rs. 1,56,59,500/- originated from the students of the Appellant Society. To support this stand, photocopies of some sample receipts, mentioning the amount of fee, name of student etc. is enclosed as Annexure A/6. It may be stated here that when the fee was collected, receipts from the receipt book of the Appellant Society were issued to the students, entries made in the individual student register and their counterfoil kept by the Society, to be recorded in the cash book. Hence, the fee was completely explained as part of the receipts of the Appellant Society. 17. It was accordingly submitted by the ld AR that there is no discrepancy as far as the Appellant Society is concerned. The cash found in the bank is explained as very much part of the receipts of the Appellant Society. There is no evidence in the order or elsewhere that the receipt were unaccounted. Secondly, there is absolutely no evidence, in either the show-cause notice or in the order dated 14.12.2018 that any ben....
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....onse to question no. 11, he has stated that approx. Rs. 2 crore fees have been collected in cash during the period 1.12.2016 to 9.12.2016. Further, the tax authorities during the course of survey have gone through the receipt vouchers issued by the Saint Wilfred College to its students towards receipts of fees and other charges collected from students as is evident from question no. 13 raised by the survey team to Ganesh Narayan Gupta wherein there is reference to vouchers and receipts as per which fees and other related charges have been collected in cash amounting to Rs. 2.15 Crores from the students. Further, we refer to the statement of Shri Mahavir Prasad, another accountant of the assessee society whose statement was recorded u/s 131 on 9.12.2016. In response to question no. 19, he has stated that they issue receipt to the students against deposit of their fees and subsequently in response to question no. 51, he has again confirmed that students have been given receipt against deposit of their fees and the same is recorded in the computers. Further, in response to question no. 9 wherein he was asked the status of cash in hand, he has stated that they prepare a daily collectio....
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.... was received and sent for deposit in its bank account and at the time of survey, it was not updated. At the same time, as we have noted above, the fact of the matter is that fee received from the students is recorded in the books of accounts as corroborated by fee receipts, individual student register maintained online in the computer system, daily cash collection summaries and relates vouchers. These documents are written/printed documents available on record and are very much part of books of accounts maintained in the regular course and clearly fall in the inclusive definition of books of accounts so defined u/s 2(12A) of the Act. Such fee receipts and related vouchers have been examined by the survey team at the time of survey as evident from the question no. 13 raised to Ganesh kumar Gupta, the accountant of the assessee society where the tax official has asked a question that based on perusal of vouchers, it is apparent that after 21.11.2016, fees and other related charges have been collected in cash amounting to Rs. 2.15 Crores. Therefore, we find that though the cash book has not be updated at the time of survey in terms of recording the movement of cash for deposit in its....
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....trust or the founder of the institution; (b) any person who has made a substantial contribution to the trust or institution, that is to say, any person whose total contribution up to the end of the relevant previous year exceeds fifty thousand rupees; (c) where such author, founder or person is a Hindu undivided family, a member of the family; (cc) any trustee of the trust or manager (by whatever name called) of the institution; (d) any relative of any such author, founder, person, member, trustee or manager as aforesaid; (e) any concern in which any of the persons referred to in clauses (a), (b), (c), (cc) and (d) has a substantial interest." 20. As per clause (cc) to section 13(3), it talks about any trustee of the trust or manager (by whatever name called) of the institution. Shri Keshav Badaya is the secretary of the assessee society and involved in its administrative affairs and thus falls under clause (cc) of section 13(3) as a related person in relation to the assessee society. The clause (e) to section 13(3) talks about any concern in which any of the persons referred to in clauses (a), (b), (c), (cc) and (d) has a su....
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....ctly for the benefit of any person referred to sub-section (3) to section 13 of the Act. It thus talks about the usage or application i.e, there has to be actual utilization or application of funds for the benefit of the related person. It doesn't contemplate a situation of intended or future application of such funds for the benefit of such person. In the instant case, firstly the funds belonging to the assessee society have been physically found in the possession of the Bank at its strong room and not in possession of Shri keshav Badaya. Secondly, such funds have not been used or applied and have been physically found and thus, there is no benefit which can be said to have actually been gained by Shri Keshav Badaya either directly or indirectly in his individual capacity by having such funds in the possession of the Bank. In light of above, we are of the considered view that the provisions of section 13(1)(c) are not attracted in the instant and the contentions so advanced by the Revenue and the ld CIT DR cannot be accepted. 23. We therefore find that it was merely a suspicion gathered through the preliminary enquiry conducted during the survey and search operations. A suspici....
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....ssee society will surely come under the cloud. In the instant case, the cash has been physically found in possession of the assessee's bank and the said cash belongs to the assessee society as corroborated by the statements of the bank employees, there is thus no basis to hold that there is any diversion of funds of the assessee society for the personal benefit of Badaya family and the same cannot be a basis to withdrawn the exemption so granted to the assessee society u/s 12AA of the Act. Non-Genuine Scholarship Expenses: 24. Briefly the facts of the case are that during the course of assessment proceedings for the AY 2014-15, the assessee society was asked by the Assessing officer and it has furnished a list of 301 students to whom the assessee has claimed to have paid a total scholarship of Rs. 25,83,142/. To verify the claim of the assessee, notices were issued by the Assessing officer u/s 133(6) of the Act to 25 students to ascertain whether they have received the scholarship from the assessee society. Out of total 25 students, replies of 16 students were not received. Letters sent to two students were returned back unserved by the postal authorities and three students d....
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....the students. The ld. Pr. CIT accordingly held that in absence of physical examination, such confirmation letters cannot be treated as conclusive proof of the genuineness of scholarship payment. It was accordingly concluded that the assessee has misused funds which were claimed as expenses in the guise of scholarship payments. 27. During the course of hearing, it was submitted by the ld AR that all the scholarship money was paid by account payee cheques. Except in the case of Yuvraj Singh, all the cheques have been cleared and debited in the bank account of the Society. A copy of the bank account of the Society showing debits due to scholarship money cheques is enclosed as Annexure A/7. No evidence has been brought on record to show that the scholarship money or even part of it has been siphoned off by the Trustees and utilised for their benefit. In the case of Yuvraj Singh, the cheque was never deposited by him in his bank account, hence, the amount was credited, as a contra entry, in the bank account of the Society. Copy of the relevant extract of the Society's bank account is annexed as Annexure A/8. This extract was also supplied with the reply to the show-cause notice, ....
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....of the Act. In the light of the same, it was finally submitted that the conclusion drawn by the ld Pr.CIT is wholly erroneous, incorrect, and needs to be rejected. 30. The ld CIT DR was heard who has relied heavily on the findings of the ld Pr.CIT. We have already taken note of the said findings and the same are not being repeated for the sake of brevity. 31. We have heard the rival contentions of both the parties and perused the material available on the record. The ld Pr CIT has raised certain apprehension about non-verifiability and genuineness of the scholarship payments made by the assessee society to its 301 students during the financial year 2013-14. The basis of such apprehension is that notices u/s 133(6) issued by the Assessing officer to sixteen students were not complied with and in two cases, notices were returned unserved, and three students have denied receiving the scholarship during the financial year 2013-14. Further, these students were not produced for verification and it was concluded that the assessee has misused funds which were claimed as expenses in the guise of scholarship payments. In response, the assessee society has submitted that all scholarship....
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....claimed as expenses in the guise of scholarship payments. We find that the documents produced by the assessee society in support of the scholarship payments have not been considered. The scholarship payments have been paid to the regular students who are enrolled in various courses conducted by the educational institutions run by the assessee society. During the course of hearing, the ld AR stated at the Bar that the criteria for such scholarship has been well laid down in terms of economic condition of the students and their parents, past academic results, etc and there is a well laid down process for seeking application from the students and after due verification and approval from the Head of the educational institution, scholarship payments are sanctioned and subsequently disbursed to the students. It is also not the case of the Revenue that these are not regular students which were enrolled with the assessee's educational institutions and that they were not eligible to receive the scholarship as per the policy framed by the assessee's educational institutions. The confirmation letters filed by the students have been placed on record and the contents thereof have not been dispu....
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....basis to disallow the said expenses limited to the extent it remain unverified, how the same can be basis to hold that the assessee society has misused the funds of the society in garb of whole of the scholarship expenses and if the said analogy is accepted, then every expense claim where the same is not proved by personal appearance of the person to whom such payment has been made would be a basis to hold that the assessee society has misused the funds of the society. To our mind, as the assessee society has documentation to support its claim, such apprehension is ill-founded and is not supported by well established legal proposition and rule of law. 35. Further, we find that the Revenue authorities have to appreciate that a student studying in a College or University cannot be equated with a regular vendor or a service provider. A student involvement is limited to the educational sphere and to a limited extent where he/she and their parents/guardians are required to pay his fees and receive scholarship wherever he/she is eligible for the same and nothing beyond that. As against that, a vendor or a service provider is in the business of supply of goods and provision of services....
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....facts of the case are that during the F.Y. 2013-14, the assessee has made a payment of Rs. 6,73,70,930/- to Rajasthan Housing Board towards allotment of land by Rajasthan Housing Board to M/s Adarsh Gyan Vidyalaya Samiti and has shown the same in its financial statements as part of land purchased during the year. For the purposes, the assessee entered into an "agreement to sell" with M/s Adarsh Gyan Vidyalya Samiti. The conveyance cum perpetual lease deed though has been executed by Rajasthan Housing Board in favour of M/s Adarsh Gyan Vidyalya Samiti, however, no registry or title transfer has been done in favour of the assessee society. 38. The ld PCIT, referring to the conditions of allotment as per allotment letter issued by Rajasthan Housing Board to M/s Adarsh Gyan Vidyalya Samiti, held that a person to whom the land has been allotted cannot transfer it to any other person. It was accordingly held that the claim of the assessee society that it has purchased the land is patently false as it is illegal for M/s Adarsh Gyan Vidyalya Samiti to sell/transfer the land to the assessee. It was further observed that M/s Adarsh Gyan Vidyalya Samiti and the assessee society have three ....
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....iety cannot legally transfer or sell the land to the assessee and therefore, it is illegal for Adarsh Gyan Society to transfer or sell the land in question to assessee. It was accordingly held that the "agreement to sale" is nothing but an illegal piece of document which has been fabricated by the assessee in an attempt to submit as false evidence before Income-tax authorities. It was accordingly held that by making payment on behalf of Adarsh Gyan Society, the assessee has used part of its income for the direct benefit of its sister concern, Adarsh Gyan Society and has therefore violated provisions of Section 13(1)(c) of the Act and consequently, Sections 11 and 12 will not be applicable in the case of the assessee. 41. The ld CIT DR has strongly relied on the aforesaid findings of ld PCIT. In his submissions, the ld AR on behalf of the assessee submitted that Adarsh Gyan Vihar Vidhalaya Society, in which some of the trustees are common as that of the assessee society, had purchased land from Rajasthan Housing Board to build a school thereon. The Society paid the initial amount of Rs. 80,46,880/- but was unable to pay the rest of the amount of Rs. 6,73,70,930/- due to paucity o....
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....ceipts. A copy of the audited a/cs of the Appellant Society for the year A.Y. 2017-18 are enclosed as proof and marked as Annexure A-13. The allegation that the purchase is not a purchase, but an investment is also incorrect, in the light of the fact that payment has been made towards purchase of the land. Hence, it does not fall within the ambit of Section 11(5) of the Act. 43. It was further submitted that even for the sake of argument, if it is taken that there is a deficiency in the papers of purchase of land in the absence of a sale deed, that does not affect the fact of purchase of land as held by the ITAT, Jaipur Bench, in the case of Indian Medical Trust v. PCIT(Central), Jaipur [2018] 99 taxmann.com 273 in following words: "Where assessee trust engaged in running various educational institutions was denied registration under section 12AA merely on ground that some part of land on which assessee had set up an University was not in the ownership of said University as per certain government notification, same was unjustified." 44. It was further submitted by the ld AR that very allegation of the Respondent that the purchase price is actually an investment not s....
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....ance of the said agreement to sell has thereafter made a payment of Rs. 6.73 Crores directly to Rajasthan Housing Board. Subsequently, Adarsh Gyan Vidhalaya Samiti, having complied with the terms and conditions of allotment letter including the requisite terms of payments, has entered into a conveyance cum perpetual lease deed with Rajasthan Housing Board which has been registered with the office of Sub-Registrar VIII Jaipur on 7.02.2014 and the relevant terms and conditions of such conveyance cum perpetual lease deed reads as under: "4. The lessee may transfer, assign otherwise part possession of the whole or any part of the said land with the previous consent of lessor. Which it shall be entitled to refuse in its absolute discretion. 5. Whenever the title of lessee in the said land is transferred in any manner what so ever the transferee shall be bound by all covenants and conditions contained herein be answerable in all respect thereof. In case the property is mortgaged to any financial institution, bank, Rajasthan State Industrial Development & Investment Corporation Ltd. (RIICO) for a loan against it, the Rajasthan Housing Board accepts the right of the finan....
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....g provisions for transfer are read in comparison to the terms of the earlier allotment letter dated 17.12.2013 wherein the transfer was not permitted, the terms of conveyance cum perpetual lease deed shall supersede the terms of initial allotment. Further, where both the parties have contractually agreed to the terms of conveyance cum perpetual lease deed, in the context of present proceedings, we cannot be guided by the initial allotment letter which stands subsumed and merged/modified by conveyance cum perpetual lease deed. Therefore, we are unable to agree with the findings of the ld Pr.CIT that Adarsh Gyan Vidhalaya Samiti cannot legally transfer or sell the land to the assessee society as there are enabling provisions, as we have noted above, in the conveyance deed which allows such transfer subject to approval and sanction of Rajasthan Housing Board. 48. Now, in terms of seeking approval and permission of Rajasthan Housing Board to transfer the land in favour of the assessee society, we find that a letter dated 14.03.2014 has been written by Adarsh Gyan Vidhalaya Samiti to Deputy Housing Commissioner, Circle-2, Rajasthan Housing Board, Jaipur available on record at Annexur....
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....rd has not been received, the conveyance deed has not been executed in favour of the assessee society. 51. We therefore find that the assessee society has entered into an agreement to sell with Adarsh Gyan Vidhalaya Samiti wherein the former has agreed to purchase an institutional plot of land which has been allotted to the latter vide conveyance cum perpetual lease deed for 99 years by the Rajasthan Housing Board. There are enabling provisions in the conveyance cum perpetual lease deed which allows such transfer subject to approval and sanction of Rajasthan Housing Board. Necessary permission has been sought from the Rajasthan Housing Board for such transfer in favour of the assessee society and the same is currently awaited and on receipt thereof, formal sale deed shall be executed in favour of the assessee society. The assessee society has already paid substantial amount of Rs. 6.73 Crores, out of total purchase consideration of Rs. 7.54 Crores in terms of agreement to sell, directly to Rajasthan Housing Board. Further, the assessee society is in effective possession of the said plot of land as it has since built a school building thereon and carrying on its educational activ....
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....(3) of the Act. 55. In order to appreciate the rival contentions, we again refer to the provisions of section 13(3) of the Act. The clauses from (a) to (cc) of section 13(3) are not applicable in the instant case as there is nothing on record that suggest that the common members have been benefitted in their individual and in their own right by such transaction. The clause (d) talks about any relative of any such author, founder, person, member, trustee or manager of the assessee society which is also not a case before us. The clause (e) talks about any concern in which any of the persons referred to in clauses (a), (b), (c), (cc) and (d) has a substantial interest. If we were to read the said clause (e) in the context of present facts, it means Adarsh Gyan Vidyalya society, being a concern in which members/trustees of the assessee society have a substantial interest. The term "substantial interest in a concern" has been defined in Explanation 3 to mean: "(i) in a case where the concern is a company, if its shares (not being shares entitled to a fixed rate of dividend whether with or without a further right to participate in profits) carrying not less than twenty per ce....
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....loyed in the society and even in the event of winding up, the assets and funds of the society have to be transferred to any other registered society with similar objects. In light of the same, we don't find any legal basis to hold that Adarsh Gyan Vidyalya Society is a related entity within the meaning of section 13(3) of the Act. In absence thereof, even where it is held that some benefit has flown to Adarsh Gyan Vidyalya Society, the provisions of section 13(1)(c) are not attracted in the instant case. 57. Further, we note that the ld Pr.CIT has raised an apprehension at the time of issuance of show-cause that the payment to Rajasthan Housing Board on behalf of Adarsh Gyan Vidyalya Society is neither a loan nor a donation but appears to be an investment not allowable u/s 11(5) of the Act and thereafter, towards the end of his order while giving his concluding findings has held that the payment made is in contravention of section 11(5) r/w section 13(1)(c) of the Act. However, how the payment is in contravention of section 11(5) has not been spelt out in his order. If we look at the provisions of section 11(5), in clause (x), it provides for investment in immoveable property as....
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....s and circumstances of the case as in ITA no. 9/JP/2019 and following the same reasoning, the ld. Pr. CIT has withdrawn the exemption by invoking 15th Proviso to Section 10(23C) of the Act and similar contentions have been raised by both the parties. Therefore, our findings and directions as contained in ITA No. 09/JP/2019 shall apply mutatis mutandis to this matter as well. The exemption granted to the assessee society U/s 10(23C)(vi) of the Act is hereby directed to be restored from the date the same was withdrawn and cancelled by the ld. Pr. CIT in terms of the impugned order. 61. In the result, the appeal of the assessee society is allowed. Order pronounced in the open Court on 18th March, 2019. ============= Document 1 कारà¥à¤¯à¤¾à¤²à¤¯ उप आवासन आयà¥à¤•à¥à¤¤ वृतà¥à¤¤ दà¥à¤µà¤¿à¤¤à¥€à¤¯ राजरपान आवासन मणà¥à¤¡à¤², अपà¥à¤°à¤µà¤¾à¤¸ फारà¥à¤®, मानसरोवर, जà....
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