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    Electronic payment acceptance requirement mandates prescribed digital channels for businesses and professions exceeding the turnover threshold.
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    Section 175 deeming rule attributes interest and dividends to the original owner or beneficial holder when securities transactions separate economic entitlement from legal receipt, applies on day to day accrual where beneficial interest existed during a year, operates irrespective of other charging provisions, allows the Assessing Officer to require ownership details, and includes a business of dealing carve out and short term record date anti arbitrage rules that ignore specified losses and adjust cost of additional securities.
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    Reference to Transfer Pricing Officer centralises arm's length price determination, binding assessments and enabling validated multi year application.
    An Assessing Officer, with prior supervisory approval, may refer determination of the arm's length price for international or specified domestic transactions to a designated Transfer Pricing Officer who issues a written order after notice and hearing; that TPO order is binding on the Assessing Officer for computing total income, and an opt in permits validated application of the TPO's determination to the two immediately following tax years subject to prescribed conditions and recomputation procedures.
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    Arm's length price determination allows limited acceptance of actual transaction price; AO may redetermine ALP after show-cause.
    Arm's length price must be determined using specified transfer pricing methods or other Board prescribed methods, selecting the most appropriate method based on transaction nature, functions and prescribed factors. If a single method yields one price that price governs; a notified tolerance permits acceptance of the actual transaction price in specified cases. The Assessing Officer may determine the arm's length price during assessment where documentation, reliability, or compliance with notice requirements is deficient, but must first give the taxpayer a show cause notice before recomputing total income on that basis.
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    Specified domestic transaction definition narrows domestic related party scope and imposes an aggregate threshold triggering special anti avoidance rules.
    Section 164 defines specified domestic transaction for the Chapter on avoidance of tax by enumerating categories of domestic dealings (cross referencing sections 122, 140(9), 140(13), Chapter VIII, section 144 and section 205(4)) and by permitting additional prescribed transactions; each item is subject to exclusion of international transactions and to an annual aggregate materiality threshold that determines applicability.
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    Associated enterprise definition expands to objective participation and dependence tests, broadening related party compliance risks.
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    A deduction from income tax payable is available to resident individual assessees in specified income bands: tax is computed first and then reduced by a rebate subject to fixed monetary caps; for incomes above the higher threshold a formulaic reduction by the excess income is prescribed, and any deduction is capped so it does not exceed tax payable under the referenced computation provision.
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    Deduction for interest on deposits: account-type ceilings differ by seniority, with senior citizens' scope including time deposits.
    Deduction for interest on deposits permits individuals (distinctly identifying senior citizens) and HUFs to claim limited deductions on interest from deposits with regulated banks, cooperative societies and Post Offices, subject to monetary ceilings and account-type limits: non-senior individuals and HUFs are restricted to interest from savings accounts excluding time deposits, senior citizens are allowed a broader deduction described as applying to savings accounts and expressly including time deposits, and no deduction is permitted where the deposit is held by or on behalf of a firm, association of persons or body of individuals; "time deposits" are defined as deposits repayable on expiry of fixed periods.
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    Time bound deduction for Producer Companies allows full tax relief for profits from defined member related agricultural activities, subject to sequencing.
    A time bound tax incentive allows Producer Companies, as defined in the Companies Act, to claim a full deduction for profits attributable to an eligible business (marketing members' agricultural produce; supplying members with agricultural inputs; processing members' agricultural produce), subject to a turnover ceiling and a sequencing rule that permits the deduction only after other Chapter deductions; the clause omits attribution, anti abuse and procedural rules, creating compliance uncertainty.
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    Deduction for co-operative societies: specified cooperative income receives preferential tax deductions, subject to governance and computation rules.
    Clause 149 permits targeted tax deductions for co operative societies by fully or partially deducting income attributable to enumerated cooperative activities (banking/credit to members, cottage industries, marketing of members' agricultural produce, supply of agricultural inputs, processing without power, collective disposal of members' labour, and fishing/allied activities), supplies by primary societies to federal cooperatives or government entities, inter cooperative investment income, and income from letting godowns; certain non specified activities qualify only up to capped amounts, governance restrictions on voting rights condition some deductions, and cooperative deductions are computed after reducing specified pre existing deductions.
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    Special tax deduction for North-Eastern undertakings grants full profit exemption for a fixed consecutive period.
    A 100% deduction of profits and gains is available to undertakings in specified North-Eastern States for ten consecutive tax years starting from an "initial tax year", contingent on commencement or substantial expansion within a discrete qualifying window, formation and newness-of-plant conditions, exclusions for specified goods and activities, a defined test for "substantial expansion", and exclusivity preventing concurrent Chapter deductions; cross-referenced provisions determine treatment of re-established entities and aggregate duration limits.
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    Deduction for research donations: tax relief for approved gifts subject to verification and specified exclusions.
    Deduction is allowed for donations to approved research associations or educational institutions for scientific or social science/statistical research, contingent on recipient approval and information furnished by the payee to the prescribed income tax authority and subject to the Board's risk based verification; deductions are excluded where the donor has business/profession income or where contributions in cash exceed the prescribed threshold, and deduction is not to be denied solely because recipient approval is later withdrawn.
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    Pension contribution deduction: employer and individual pension contributions receive tax relief, with caps and deeming rules affecting receipt.
    Section 124 allows deductions for employer contributions to Central Government notified pension schemes subject to employer type percentage ceilings and for individual deposits into such schemes subject to an overall statutory cap; parent or guardian deposits for minors are aggregated with the individual cap. The provision defines salary for this purpose to include dearness allowance where employment terms so provide, disallows duplicate deduction where relief was claimed under the related provision, and deems amounts received on closure, opt out, or as annuity taxable in the year of receipt, with limited exceptions for nominee/parent/guardian receipts on death.
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    Loss carry-forward restrictions: beneficial ownership and voting-power continuity determine entitlement to set off historic losses.
    The section restricts carry forward and set off of losses on change in firm constitution, succession other than by inheritance, and change in shareholding of non-public companies unless continuity of beneficial ownership of shares carrying not less than fifty-one percent of voting power is maintained or specified exceptions (death, gift to relative, certain amalgamations/demergers, insolvency resolution plans with opportunity to be heard, tribunal-approved restructuring, relocation, and a start-up carve-out) apply.

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      Corporate Laws

      Small Industries Development Bank of India versus M/s. Sibco Investment Pvt. Ltd- Legal Position of NBFC in a civil suit.

      2 June, 2022

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      2022 (1) TMI 170 - Supreme Court

      Legal Position of NBFC in a civil suit.

      Section 45 MB of the RBI Act 1934. - Power of bank to prohibit acceptance of deposit and alienation of assets, Section 45 MC - Power of Bank to file winding up petition.

      Section 35A of the Banking Regulation Act, 1949 vests power in the RBI to give directions to banks and can take action, "to prevent the affairs of any banking company being conducted in a manner detrimental to the interests of the depositors or in a manner prejudicial to the interests of the banking company"

      A conjoint reading of the statutory provisions, makes it abundantly clear that for ‘public interest’ the RBI is empowered to issue any directive to any banking institution, and to prohibit alienation of an NBFC’s property.

      The term ‘Public interest’ has no rigid definition. It has to be understood and interpreted in reference to the context in which it is used. The concept derives its meaning from the statute where it occurs, the transaction involved, the state of society and its needs.

      It is not necessary for RBI to mention a specific provision before issuing directions, for it to have statutory consequences. All that is required is the authority under the law, to issue such direction.

      Therefore the RBI under Section 45-MB of the RBI Act, 1934 and 35-A of the Banking Regulation Act, 1949 has the requisite authority to issue the communication dated 09th June, 1997. Now the omission by the RBI to mention any enabling provision, doesn’t change the nature and status of the direction.

      The statutory arrangement and interpretation persuades to hold that actions in furtherance of grounds of ‘public policy’ by the RBI was justified, for issuing the Notification dated 10.04.1997. The notification itself clearly mentioned that it is issued for the benefit of "depositors and creditors" of CRB Capital.

      The actual status of the RBI Notification would have a bearing on the claim against the defendant in the suit and subsequent proceeding/s. The plaintiff, as can be noted, always had the option of challenging its legality but they have never specifically challenged those in the Suit. In a way the plaintiff " waived its right" by not challenging the RBI notification then/at that past point of time in the suit proceedings.

      The principle of waiver/acquiescence is applicable here.

      When the legality of the RBI Notification is not under challenge, relief can’t be granted in the Suit without determining its "legality". This in our perception can by itself, put a quietus on the issue at hand - the plaintiff cannot be granted parity with its predecessor-in-interest, Shankar Lal Saraf, who was paid interest which accrued in July, 1997 despite the RBI directive of 09.06.1997.

      The defendant defended this fallacy/aberration by clarifying that the payment to Shankar Lal Saraf was made before the defendant was in receipt of the RBI directive.

      Hence, the plaintiff cannot claim any advantage for themselves or parity with its predecessor-in-interest, on this cause. It amounted to sub-silencio acceptance.

      Suit barred by constructive res judicata.

      The cause of action for the plaintiff accrued the first time, when the defendant allegedly failed to pay timely interest. Since such a claim was not raised in the writ court, the subsequent Suit of SIBCO is barred by the principle of Constructive Res Judicata.

      Section 441(2) of the Companies Act, 1956 reveals that winding-up proceedings other than voluntary winding-up, are said to have commenced from the date of presentation of petition - A conjoint reading of Section 531 and 441(2) of the Companies Act, 1956 prima facie reveals that any transfer of property by or against a company in involuntary winding up, the suspect spell for deemed fraudulent transaction is six months before presentation of the winding up petition.

      In the present case, the petition for winding-up was submitted by RBI on 22.05.1997 and admittedly, the transfer in Shankar Lal Saraf’s favour was executed in February, 1997. The defendant’s contention as to the transfer being in the suspect spell, may be deemed fraudulent, cannot be rejected. 

      A question arose whether the present suit is barred by Constructive res judicata- It being decided that the cause of action for the plaintiff accrued the first time, when the defendant allegedly failed to pay timely interest. Since such a claim was not raised in the writ court/court of first instance, the subsequent Suit of SIBCO is barred by the principle of Constructive Res Judicata.

      This narrative makes us understand that a NBFC governed by the Banking  Regulation Act, 1949 and the  Reserve Bank of India Act, 1934 along with Section 531 and 441(2) of the Companies Act, 1956 is too subject to the common law principles and the Code of Civil Procedure, 1908 when in a civil suit before a Court of law.

       


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      2022 (1) TMI 170 - Supreme Court

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