TaxTMI 
TaxTMI 
2023 (2) TMI 1443
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....in the case of the assessee was conducted on 13.12.2012 in the office premises and factory premises of the assessee and the residential premises of the directors. Notice u/s.153A of the Act came to be issued and the assessment came to be completed u/s.153A of the Act for all the impugned assessment years on 31.03.2015. It was the submission that the assessment orders have been served by hand on 08.04.2015. It was the submission that these assessment orders were not passed on 31.03.2015 but those orders were passed subsequently and ante dated. It was further submitted that in respect of the issue of approval granted u/s.153D of the Act, the satisfaction of the Addl. Commissioner had been obtained as early as on 27.03.2015. Subsequent to the approval u/s.153D of the Act, notice u/s.142(1) of the Act had been issued on 30.03.2015 and the assessee had responded to the same only on the evening of 31.03.2015. It was the submission that the assessee having responded only in the evening of 31.03.2015, it was impossible for the AO to have passed assessment orders on 31.03.2015 itself. On this ground, the ld. AR of the assessee submitted that the assessment orders were passed subsequent to 3....
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....rned CIT-Departmental Representative does contain the entry in respect of the date of assessment order. DNCR also does mention the date of the assessment order as 30th Dec., 2016. However, DNCR does not contain the date of the entry made in respect of the assessment order. It only mentions the date of the assessment order as 30th Dec., 2016. Therefore, we are of the view that DNCR register does not help the case of the Revenue. 8. Learned CIT-Departmental Representative has placed before us the file of the Jt. CIT, wherein he has granted the approval under s. 153D in respect of the assessment order on 30th Dec., 2016. Again, this does not help the Revenue insofar as it is only in respect of the approval under s. 153D from the Jt. CIT. It does not prove that the order has been passed on 30th Dec., 2016. A perusal of the order of the Co-ordinate Bench of this Tribunal in the case of Nidan (supra) clearly shows that this issue has been considered by the Tribunal, wherein it is held that the assessment order therein is barred by limitation. The order of the Co-ordinate Bench of this Tribunal in the case of Nidan (supra) has also been upheld by the Hon'ble jurisdictional Hi....
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....d in the assessment folders. Copies of the final assessment orders may be sent to this office for record." 7. It was further submitted that admittedly if the bench is of the view that there is an error insofar as the assessment order dated 31.03.2015 was passed without proper approval granted u/s.153D of the Act, the same being a technical breach, therefore, the issues must be restored to the file of the AO for obtaining the proper approval and then proceed thereon. He placed reliance on the decision of the Hon'ble Jurisdictional High Court in the case of Shiv Kumar Agarwal, reported in 186 ITR 734 (Orissa), which has been followed by the coordinate bench of this Tribunal in the case of Gobardhan Matia in IT(SS)A Nos. 62-66/CTK/2013, order dated 22.09.2022, wherein the Tribunal in para 12 has held as follows :- "12. Let us now for a moment assume that there has been violation of Section 153D of the Act. The consequence of the same would not be annulment of the assessment order. The provision of section 153D is an administrative procedure in the course of assessment. The breach of such administrative procedure at best could lead to the assessment proceedings being redone....
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....balance sheets, other records, material available on records, appraisal report, etc. Finally in the last paragraph on last page of his approval letter dated 27.03.2015 (page-41 of paper book (Volume-1) filed by the ld. AR of the assessee, the Addl. CIT, Range-1, Bhubaneswar has directed that after making requisite inquiries and verifications, the final assessment orders should be passed expeditiously as per his approval. In the second last paragraph of letter dated 27.03.2015 on last page (page-41 of the paper book), the Supervisory Officer has categorically mentioned that "the draft orders are approved as per statutory requirement u/s. 153D" subject to certain enquiries/verification/investigations to be carried out by the A.O. He has thus directed the A.O. not to seek further approval and only asked that copy of final assessment orders should be sent to his office for record. In view of above facts, the A.O. was not required to seek further approval from his Addl. CIT, Range-1, Bhubaneswar. a) The facts of the present case do show that the Supervisory Officer (Addl. CIT, Range-1, Bhubaneswar) has duly applied his mind; he has gone through the records; he....
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....ction that can render the assessment order invalid. The act of Administrative Approval by Supervisory officer does not take away the quasi-judicial powers which still vests in AO and therefore Administrative Act cannot invalidate the assessment order. Charging sections fix the liability to tax and any violation of machinery section will not render the assessment order void. The Administrative order and judicial orders are separate. The subject matter of the challenge in the present appeal is assessment order for which the approval has been granted therefore the approval itself cannot be the subject matter of adjudication. e) It is further submitted that the recording of sanction or approval is not required to be made in a particular manner. What could be challenged before the Tribunal is want of sanction and for that the reliance is placed on the decision of the Mumbai Tribunal in the matter of Pratibha Pipes & Structural Ltd. vs. DCIT in ITA No.3874/Mum/2015 for the proposition that the Approval under section 153D of the Act is an Administrative procedure which requires to be complied with by the officers who arc discharging the assessment functions (para-16 to 18 on page....
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....the Act but on the ground that the approval u/s.153D was given in a mechanical manner, the assessment had been set aside. It was the submission that Seerajudin & Co. is the main case in these appeals. It was the submission that in the said decision of the Co-ordinate Bench of this Tribunal, it had been categorically held that the approving authority has not gone into the relevant records and draft assessment order prior to granting the approval to the Assessing officer for passing the assessment orders. It was the submission that consequently, in the absence of approval u/s.153D being shown by the revenue, the assessment is liable to be annulled. 8. In reply, ld CIT DR drew our attention to the order of assessment of last page, wherein, it has been mentioned that the Addl. CIT, Range-1 has given the approval. It was the submission that in Serajuddin & Co, in the assessment order, this was not mentioned and that is why the approval u/s.153D of the Act was called out. It was the further submission that a perusal of the grounds raised by the assessee showed that the challenge was in respect of the issue that the copy of the approval u/s.153D was not enclosed with the order. I....
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.... no need for the Jt. CIT to give a hearing to the assessee before granting approval. He also placed reliance on the decision of the Co-ordinate Benches of the ITAT Mumbai in the case of Rafique Abdul Hamid Kokani Vs DCIT 113 Taxman 37, wherein also, similar finding has been given. It was the submission that in regard to the issue of approval, the same being an administrative action, no opportunity was required to be given to the assessee much less copy of the approval to be granted to the assessee along with the assessment order. 9. We have considered the rival submissions. A perusal of section 153D provides that before passing the assessment order by the Assessing officer below the rank of Jt. CIT, prior approval is to be taken from the Jt. CIT. The proviso thereto provides for the prior approval from the Pr. CIT or Chief Commissioner of Income tax under section 144BA (12). Ld AR request that the Tribunal should call for the assessment records and verify the approval u/s.153D does not hold water insofar as the Tribunal is an appellate authority and it is to decide the issue before it on the basis of the facts as are available before it. True, the Tribunal is the highest f....
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....ave any impact in relation to provision of section 153D of the Act, though, admittedly, both 153D and 158BG does fall under Chapter XIV B of the Act. 12. Let us now for a moment assume that there has been violation of Section 153D of the Act. The consequence of the same would not be annulment of the assessment order. The provision of section 153D is an administrative procedure in the course of assessment. The breach of such administrative procedure at best could lead to the assessment proceedings being redone from the point where the breach took place. This view is supported by the decision of the Hon'ble Jurisdictional High Court in the case of Shiv Kumar Agarwal, 186 ITR 734 (Ori). In these circumstances, we are of the view that the decision of the Co-ordinate Bench of this Tribunal in the case of Serrajudin & Co (supra) does not apply to the facts of the assessee's case. 13. It is an admitted fact that the revenue has not placed the approval under section 153D of the Act before the Tribunal as mentioned earlier. The Tribunal has no business to call for the approval unless a specific allegation has been raised through affidavit under Rule 10 of the ITAT Rules. O....
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.... aside and restored to the file of the AO to the point of the draft assessment order to proceed from such point only and obtain necessary approval from the appropriate authority and proceed thereafter. However, as we are inclined to restore the issue to the file of the AO, we feel that in the interest of natural justice, the assessee should also be granted another opportunity to substantiate its case before the AO, insofar as no evidences have been filed by it before the AO. In these circumstances, in the interest of natural justice, the issues in these appeals are restored to the file of the AO for re-adjudication after granting the assessee adequate opportunity of being heard. The assessee shall be at liberty to raise all grounds as desired by it before the AO in the course of set aside assessment proceedings. If the assessee adopts the course of non-cooperation before the AO, even in the set aside proceedings, the AO shall be at liberty to draw adverse inference. No other grounds have been argued before us. 16. In the result, appeals of the assessee and that of the revenue for all the assessment years are partly allowed for statistical purposes". Considering th....
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....5) held that assessment proceedings generated by issuance of a notice under section 153A(1)(a) can be concluded against interest of assessee including making additions even without any incriminating material being available against assessee in search under section 132 on basis of which notice was issued under section 153A(1)(a) of the Act. The observations of the Hon'ble Kerala High Court in para-7, 8 and 9 are reproduced as under: "7. In so far as the issue as to whether it is necessary that incriminating materials should be unearthed in a search under Section 132 of the Act to sustain a notice issued under Section 153A(1)(a) is concerned, the issue stands covered in favour of the Department as per the judgment of this Court in St. Francis Clay Decor Tiles's case (supra) and Promy Kuriakose's case (supra) though the second among them relates to a third person to the search as well; which cases would fall under Section 153C of the Act. We, therefore, answer the said question stating that for the issuance of a notice under Section 153A(1)(a), it is not necessary that the search on which it was founded should have necessarily yielded any incriminating material ag....
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....ment by determining the amounts on a meaningful and appropriate application of the cash flow statement by rearranging the entries thereof. That activity carried out by the assessing authority, though to a larger extent, was found against by the CIT (Appeals), has found disapproval at the hands of the Tribunal which is the last fact finding authority. We see that the decision of the Appellate Tribunal cannot be critisised as unreasonable, perverse or unavailable on the face of record. Resultantly, these appeals fail". It may please be noted that the Hon'ble Kerala High Court has duly noted the contrary decision of Hon'ble Delhi High Court in the case of Kabul Chawla (380 ITR 573), and Kurele Paper Mills (P.) Ltd. (380 ITR 571) and Hon'ble Mumbai High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd. (374 ITR 645) while holding the decision in favour of Revenue. ii.) The Hon'ble Allahabad High Court in the case of CIT vs. Raj Kumar Arora (52 taxmann.com 172) held that the Assessing Officer has power to reassess returns of assessee not only for undisclosed income found during search operation but also with regard to material ....
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....hile relying upon the decision of a Coordinate Bench of the Tribunal in the case of Anil Kumar Bhatia (supra). We find that the said decision of the Coordinate Bench of the Tribunal was set aside by the Delhi High Court in CIT v. Anil Kumar Bhatia [2012] 24 taxmann.com 98/211 Taxman 453. We find that the Tribunal only dismissed the appeal on this legal issue and had not considered the matter on merits". iii.) The Hon'ble Kerala High Court in the case of CIT vs. St. Francis Clay Décor Tiles (70 taxmann.com 234) held that neither under section 132 or under section 153A, phraseology 'incriminating' is used by Parliament, therefore, any material unearthed during search operations or any statement made during course of search by assessee is a valuable piece of evidence in order to invoke section 153A. The observations of the Hon'ble High Court in para-20 & 21 are reproduced as under: "20. On a plain reading of Section 153A, it is clear that once search is initiated under Section 132 or a requisition is made under Section 132A after the 31st day of May 2003, the Assessing Officer is empowered to issue notice to such person requiring him to furnish....
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....case of Filatex India Ltd. vs. CIT (49 taxmann.com 465) held that during assessment under section 153A, additions need not be restricted or limited to incriminating material, found during course of search. The observations of the Hon'ble High Court in para-2 are reproduced as under: "2. On the first question, we note that the Assessing Officer, in the proceedings under section 153A of the Act, had made several additions, relying upon the incriminating material found in the course of search, which was conducted on 18th January, 2006 and subsequent dates. A perusal of the impugned order by the Tribunal would disclose that incriminating material including statement of Sanjay Agrawal, GM (Marketing) have resulted in additions, which have been upheld. It is not the case of the appellant-assessee that initiation of proceedings under Section 153A was bad or unwarranted in law as no incriminating material was found during the search. The contention raised by the appellant- assessee is that the addition, which is the subject matter of questions No. (ii) and (iii), was/is not justified in the assessment order under section 153A, as no incriminating material was found concerning ....
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....o close such enquiry. 25. If there is power to do something under the Act, the action taken in the fiscal matters cannot be set aside in exercise of the writ jurisdiction on the ground that such power is to be exercised needlessly, without any purpose. The exercise of power in such case can only be challenged, if the power is being exercised with ulterior motive and mala fide intentions. It is not open for the petitioner to contend before the writ court that the exercise of power, which admittedly exists in the authority, will expose the petitioner to assessment for the same period on which assessing authority has already recorded satisfaction". vi.) Reliance is also placed on the decision of Hon'ble Delhi High Court in the case of CIT vs. Chetan Das Lachmandas (25 taxmann.com 227) wherein it was held that there is no condition in section 153A that additions should strictly be made on basis of evidence found in course of search or other post-search material or information available with Assessing Officer which can be related to evidence found. It was further held that seized material could also be relied upon to draw inference that there were similar transacti....
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....each AY on the basis of the findings of the search and any other material existing or brought on the record of the AO. vii. Completed assessments can be interfered with by the AO while making the assessment under Section 153 A only on the basis of some incriminating material unearthed during the course of search or requisition of documents or undisclosed income or property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment. As held in para-iv, it is not necessary that the additions should be strictly made on the basis of evidence found in the course of the search, or other post-search material or information available with the AO which can be related to the evidence found however the assessment made by the A.O. should not be arbitrary. In the present case, the post search inquiries conducted by the Investigation Wing revealed that the unsecured loan received from Jai Matadi Sales Pvt. Ltd. was not genuine and it was a shell company. Hence such post search information was rightly used by the A.O. It must be appreciated that Revenue's appeal against the decision of Hon&#....
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.... is stated that the A. O. should "serve on the assessee" as compared to the language used in section 153(1) of the Act. The legislature in its wisdom has not used the term "shall be served on the assessee" U/s. 153(1) for any assessment order or Demand Notice. Similarly Section 263(2) states that " No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which order sought to be revised was passed." Thus "made" shall imply that the Pr. CIT should make the revision order by that date however there is no mention about service of revision order u/s.263 of the Act. It is cardinal rule of construction that when the words of a Statute are clear, plain and unambiguous, then the Courts are bound to give effect to that meaning irrespective of the consequences. It is said that the words themselves best declare the intention of the law giver as held by the Hon'ble Supreme Court in the case of Union of India v. Tata Chemicals Ltd. (363 ITR 658) (para-22). a) In the present case, the assessment orders are dated 31.03.2015. There is no evidence that these were ante-dated. There is no evidence to the e....
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....ction 17A(1)(a) of the Income Tax Act, 1957, requires that an order of assessment should be made within the prescribed period. It does not further require that it should be communicated within the prescribed period. An order must be deemed to have been made on the date on which it is purported to have been made. Therefore, an assessment order purporting to have been made on 31st March, 1979, but served on the assessee on 20th April, 1979, is deemed to have been passed in the eye of law on 31st March, 1979 and not barred by limitation under section 17A(1)(a). e) Similarly in the case of India Ferro Alloy Industry Pvt. Limited Vs. Commissioner of Income Tax (202 ITR 671), the Hon'ble Calcutta High Court held that in its opinion, what was required for completion of the assessment was the determination of the tax liability and issue of demand notice but certainly not the service of the same on the assessee. In view of above cited decisions and facts of the present case, it is clear that the AO had passed the assessment order within limitation period i.e. 31.03.2015. f) The Hon'ble Cuttack ITAT in the case of Sophia Study Circle Vs. ITO, Ward-2(1), Cuttack in I....
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....l ground raised by the assessee stands rejected". In the case of Sophia Study Circle, the Hon'ble Cuttack ITAT differed from the earlier decision in the case of Durga Condev Pvt. Ltd. in ITA No.162/CTK/2012 dated 18.05.2012. Hence there is a judicial precedent which needs to be followed. g) It may please be appreciated that in case of an assessee, facts and circumstances being same, the Tribunal is required to follow order passed by it. The Hon'ble Cochin Tribunal in the case of ACIT vs. Chandragiri Construction Co. (21 taxmann.com 167) (TM) observed in para-8 of the decision of Hon'ble Vice President (Third Member) as under: "The Tribunal is to follow the decision of another Bench where facts are the same. This is a treaty law. The only other alternative is to refer the matter to the larger bench if the Members of this Bench are not willing to follow the earlier order. In this case, there is no dispute that the facts and circumstances are the same as appearing in the assessment year 2002-03 except change in figures and it is also true that the very same Members decided the issues for assessment year 2002-03 in favour of the assessee. In such ....
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....nder section 263 (2) of the Act. Receipt of the order passed under section 263 by the assessee has no relevance for the purpose of counting the period of limitation provided under section 263 of the Income Tax Act. In the present case, the order was made/passed by the learned Commissioner on 26-3-2012 and according to the department it was dispatched on 28-3-2012. The relevant last date for the purpose of passing the order under section 263 considering the fact that the assessment was for the financial year 2008-09 would be 31-3-2012 and the order might have been received as per the case of the assessee-respondent herein on 29-11-2012. However as observed hereinabove, the date on which the order under section 263 has been received by the assessee is not relevant for the purpose of calculating/considering the period of limitation provided under section 263 (2) of the Act. Therefore the High Court as such has misconstrued and has misinterpreted the provision of sub-section (2) of section 263 of the Act. If the interpretation made by the High Court and the learned ITAT is accepted in that case it will be violating the provision of section 263 (2) of the Act and to add something which ....
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....y, then it would have been incumbent upon the appellate authority to inform the assessee about the result of such enquiry so as to afford an opportunity to the assessee to make his submission with regard thereto. But the appellate authority had no such obligation to disclose the assessment records to the assessee before taking them into account at the time of hearing of the appeal. An appellate court cannot be prevented from perusing the lower court records. It is a strange submission to make that the lower court records could not have been perused without giving an opportunity to the assessee. The submission that the learned Tribunal was justified in drawing an adverse inference is altogether without any merit. The learned Tribunal was hearing an appeal. The learned Tribunal was not taking evidence of the matter as a Court at the first instance would do. The question for consideration was whether the order dated 31st December, 2008 could be said to have been passed on 31st December, 2008 when the demand notice together with a copy of the order was served after 47 days. A period of 47 days time is not time long enough which can even make anyone suspicious as regards the correctness....
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.... order passed on 27th April, 2007 is barred by limitation on the facts and circumstance of the case ? 2. Whether the Tribunal is correct in law in holding that the Assessing Officer does not have the power to unilaterally withdraw the direction for audit under section 142(2A) of the Income Tax Act as the original direction was made with the approval of the commissioner of Income Tax on the facts and circumstance of the case ? 3. Whether the Tribunal was correct in law in holding that the assessment order passed on 27th April, 2007 is barred by limitation as successive direction under section 142(2A) is not permissible and the second direction given to obtain the audit report before 28th February, 2007 is to elongate the assessment proceedings and also contrary to section 142(2C) of the Act on the facts and circumstance of the case ? 4. Whether the assessment order is barred by limitation as it was made beyond the period of limitation on the fact and circumstances of the case ?" On appeal, the Hon'ble Karnataka High Court held that the period prescribed under law being sixty days, the assessment orders were required to be issued on or before 2....
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....of Shantilal Godawat & Others vs. ACIT (2009) 30 DTR 413, wherein it was held that "the assessment order passed on 28.12.2007 but served on 02.01.2008, beyond the period of limitation of 31.12.2007 was barred by limitation and thus non-est in law". On appeal, the Hon'ble Mumbai ITAT held in paras-7 to 8 as under: "7. We have carefully considered the submissions of the rival parties and perused the material available on record. We find that there is no dispute that the impugned assessment order was passed on 30.12.2009. It is also not in dispute that the same was received by the assessee within three days i.e. on 2.1.2010. Under the provisions of section 153 of the Act, it has been mentioned that the order of assessment has to be made within twenty one months from the end of the relevant assessment year i.e. in the case of the assessee on or before 31.12.2009. It is not necessary that the order of the assessment should be communicated to the assessee or that notice of demand in pursuance thereof should be served on him within the above period. The assessee placed no material on record to show that the order of assessment was not passed on 30.12.2009. Merely because acco....
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....through speed post by the office staff on 04.04.2015. According to the arguments of the assessee the order should be served up to the end of the financial year i.e. 31.03.2015 but the order has been received by the assessee on 04.04.2015, which is illegal. In this regard, we refer to the provisions of Section 263(2) of the Act, which reads as under "263(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed." From the record, it is clear that the assessment order u/s.143(3) of the Act was passed on 22.03.2013 and the Pr. CIT has passed his order on 30.03.2015, therefore, the order is within two years from the relevant date. From the reading of the provisions of Section 263(2) of the Act, it is clear that there is no mention about the "service" of the order, however, it is only mentioned that the order shall be "made". With regard to "service" it has clearly been defined in the section 143(2) of the Income Tax Act but in section 263 of the Act nowhere about service of order has been mentioned. Therefore, this argument of the assessee with regard to ground No.1, is dismissed".....
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.... in respect of the statutory document, such administrative act has to be done in respect of that statutory document. Failure of such act or the waiver of such act would lead to a statutory document being passed erroneously. Admittedly, such document does not become void ab initio. This being so, respectfully following the decision of the Hon'ble Jurisdictional High Court in the case of Shiv Kumar Agrawal (supra) as also the coordinate bench of the Tribunal in the case of Gobardhan Matia(supra), as the irregularity in the assessment proceedings has taken place when the final assessment order has been passed without obtaining the approval of the Addl. CIT, we are of the view that the issue in this appeal would have to be restored to the point before passing of the impugned assessment order to obtain the approval of the Addl. CIT and then to proceed therefrom in accordance with law. Consequently, this ground of assessee's appeal for all the assessment years under consideration is partly allowed for statistical purposes. 13. Coming to the issue of time barring of the assessment order is passed u/s.153A of the Act allegedly on 31.03.2015. It is an admitted fact that notice u/s.142(1)....
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.... dismissed as not argued. 15. As we have already quashed the assessment order on account of being barred by limitation, the appeals filed by the assessee stand allowed. 16. In the result, all appeals of the assessee stand allowed. Order dictated and pronounced in the open court on 01/02/2023. ============= Document 1 à¤à¤¾à¤°à¤¤ सरकार GOVERNMENT OF INDIA आयकर आयà¥à¤•à¥à¤¤ कारà¥à¤¯à¤¾à¤²à¤¯(लेखा परीकà¥à¤·à¤¾) OFFICE OF THE COMMISSIONER OF INCOME TAX ( AUDIT & ITAT ) तृतीय मंजील, आयकर à¤à¤µà¤¨ (लेखा परीकà¥à¤·à¤¾) , राजसà¥à¤µ विहार, 3RD FLOOR, AAYAKAR BHAWAN ANNEXE, RAJASWA VIHAR, HEGPER- 751007 / BHUBANESWAR - 751007 Phones: 0674-2588715 ( FAX ) 0674-2589712 INCOME TAX DEPARTMENT No.CIT./Audit & ITAT/BBSR/BP/2022-23/205/ Dated 30th December, 2022 To, The ACIT, Circle-1(2) Bhubaneswar Sub: Documents....