9911796707
TMI Blog2015 (9) TMI 138X X X X Extracts X X X X X X X X Extracts X X X X ..... has given a categorical finding that the assessee has duly produced all the necessary details and that the assessee has duly identified the capital portion of the expenditure incurred and the amount of the improvements expenses which were of revenue in nature. We also find that it is a settled law that powers and duties of the Commissioner of Income Tax (Appeals) are coterminus with that the Assessing Officer. Hence, in our considered opinion, there is no need to interfere with the finding of the learned Commissioner of Income Tax (Appeals) - Decided in favour of assessee Addition on account of direct selling agent commission expenses - CIT(A) deleted the addition - Held that:- Identical issue has been decided in favour of the assessee in the preceding year wherein held that the expenditure is incurred once for all in the form of stamping duty as well as commission paid to the direct selling agents for procuring the loan assignments and it is not dependent upon the working out of the agreements ultimately entered into between the assessee and the customers. Since the commission is paid to the direct selling agents, for their services in sourcing hire in the year in which the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reation of any capital asset, tangible or intangible, and thus, the question of treating the same as capital expenditure does not arise. Also expenses on issue of debentures, whether convertible or not, is allowable as a deduction in computing the income of the assessee.- Decided in favour of assessee Addition on account of loan acquisition costs - CIT(A) deleted the addition - Held that:- As decided in PY The relevant provisions of the act recognize only capital or revenue expenditure. Indisputably, the amount claimed by the assessee in these three assessment years is revenue in nature. Deferred revenue expenditure denotes expenditure for which a payment has been made or a liability incurred, which is essentially revenue in nature but which for various reasons like quantum and period of expected future benefit etc., is written off over a period of time e.g. expenditure on advertisement, sales promotion etc. There is no material before us to infer that the aforesaid expenditure resulted in creation of any capital asset, tangible or intangible, and thus, the question of treating the same as capital expenditure does not arise. - Decided in favour of assessee Addition on accoun ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nue : Sh. Vivek R. Wadekar, CIT DR Sh. Rahul Garg, Sr. DR ORDER PER N.K. SAINI, A.M. These two appeals by the department are directed against the separate orders dated 27.03.2012 and 26.10.2012 for the assessment years 2007-08 and 2008-09 respectively, passed by the ld. CIT(A)-XX, New Delhi. These appeals were heard together so these are being disposed off by this consolidated order for the sake of convenience and brevity. 2. First we will deal with the appeal for the assessment year 2007-08. Following grounds have been raised in this appeal: 1. The Ld. CIT(A) has erred on facts and in law in deleting addition of ₹ 24,40,36,690/- on account of Advertisement and publicity expenses. 2. The Ld. CIT(A) has erred on facts and in law in deleting addition of ₹ 21,16,50,310/- on account of lease hold improvements expenses. 3. The Ld. CIT(A) has erred on facts and in law in deleting addition of ₹ 1,00,55,42,364/- on account of direct selling agent commission expenses. 4. The Ld. CIT(A) has erred on facts and in law in deleting addition of ₹ 5,28,33,372/- on account of loss on sale of repossessed assets. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2. Advertisement, publicity and sales promotion expenses 24,40,36,690 Deferred over a period of 5 years 3. Leasehold improvement expenses 21,16,50,310 Capitalized as part of building and depreciation @ 10% has been allowed. 4. Loan acquisition cost 51,34,55,174 Deferred over a period of 3 years 5. Direct Selling Agent Commission expenses 100,55,42,364 Deferred over a period of 3 years 6. Loss on sale of repossessed assets 5,28,33,372 Held to be a capital loss 7. Club expenditure 59,849 Held to be non business expenditure ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dras Industrial Corporation (supra), the expenditure can be allowed to be spread over, that too, when the assessee chooses to do so. 8. Respectfully following the decision of Hon ble Delhi High Court, this ground is allowed. 6. In view of the above we do not see any merit in the departmental appeal on this issue. 7. The next issue vide Ground No. 2 relates to the deletion of addition of ₹ 21,16,50,310/- made by the AO on account of lease hold improvements expenses. As regards to this issue the ld. Counsel for the assessee submitted that this issue has been decided by the ITAT in its aforesaid order dated 20.02.2015 wherein the relevant findings had been given in para 9 to 14 of the said order. The ld. DR could not controvert the aforesaid contention of the ld. Counsel for the assessee. 8. After considering the submissions of both the parties, it is noticed that an identical issue was a subject matter of adjudication in the preceding year in assessee s own case wherein vide order dated 20.02.2015, the issue has been decided in favour of the assessee and relevant discussion is made in paras 9 to 14 which read as under: 9. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... whether the expenditure incurred on leasehold improvements was capital or revenue in nature. A large number of premises are taken on lease by the assessee throughout the country and expenditure on improvements of these lease premises was incurred by the assessee. The assessee has treated part of the said expenditure as capital in nature and deprecation thereon. In so far as expenditure to the extent of ₹ 1.52 crores is concerned, the same is treated as revenue in nature. 21. Mrs. Bansal may not be correct in her submission that the Commissioner of Income Tax (Appeals) simply accepted the assertion of the assessee. The order of the CIT reveals that the plethora of documents in respect of expenditure incurred on leasehold improvements to the extent of ₹ 1.52 crores was filed at pages 282 to 336 of the paper book. The order of the Commissioner of Income Tax (Appeals) clearly reveals that he had perused the bills filed by the appellant and also verified its various assertions . Thus the Commissioner of Income Tax (Appeals) accepted the sand of the assessee only after verification of the records and arriving at a finding of fact that the expenditure o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... see is allowed. 9. So, respectfully following the earlier order of the Tribunal dated 20.02.2015 in assessee s own case, we do not see any merit in this ground of the departmental appeal. 10. The next issue vide Ground No. 3 relates to the deletion of addition of ₹ 1,00,55,42,364/- made by the AO on account of direct selling agent commission expenses. As regards to this issue the ld. Counsel for the assessee submitted that it is covered vide para 21 of the order dated 20.02.2015 in ITA No. 4776/Del/2010 for the assessment year 2006-07 in assessee s own case. The ld. DR could not controvert the aforesaid contention of the ld. Counsel for the assessee. 11. After considering the submission of both the parties, it is noticed that an identical issue has been decided in favour of the assessee in the preceding year vide para 21 of the order dated 20.02.2015 and the relevant findings therein read as under: 21. We have considered the submissions of both the parties and have perused the record of the case. It is not disputed that the facts are identical to assessment years 2001-02 to 2005-06. We find that Tribunal in para No. 13 has observed as under: ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the financing is spread over and, therefore, expenditure on the aforesaid counts was required to be spread over. The ITAT, however, denounced this reasoning of the Commissioner of Income Tax (Appeals) and accepted the plea that the expenditure incurred had nothing to do with the period of length of time and had no linkage, whatsoever, to any period, the entire expenditure was allowable in the year in which it was incurred. The Tribunal has further held that the expenditure is incurred once for all in the form of stamping duty as well as commission paid to the direct selling agents for procuring the loan assignments and it is not dependent upon the working out of the agreements ultimately entered into between the assessee and the customers. Since the commission is paid to the direct selling agents, for their services in sourcing hire in the year in which the loan is disbursed, it is to be allowed as business expenditure. The Tribunal, to arrive at this finding took into consideration the clauses of the agreement relating to mode of payment of consideration as well as termination clause in the agreement. Thus, as the entire expenditure was incurred which admittedly have nexus w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... been on revenue account and hence the advantage secured was in the field of revenue and not capital. As a result of the expenditure incurred there was no addition to the capital assets of the assessee-company and no change in its capital structure. The pipelines, etc., which might have been regarded as capital assets and which came into . 17. We are in agreement with the aforesaid view taken by the Tribunal and hold that the expenditure was required to be allowed as revenue/business expenditure incurred in that year. The reasons given by us while allowing the advertisement and publicity expenditure will apply here as well. 13.1 In the light of aforesaid view taken by the Hon ble Jurisdictional High Court, especially when the Revenue have not placed before us any material controverting the aforesaid findings of the ld. Commissioner of Income Tax (Appeals) so as to enable us to take a different view in the matter nor brought to our notice any contrary decision, we have no hesitation in upholding the findings of the ld. Commissioner of Income Tax (Appeals). Therefore, ground No. 5 in the appeal of the Revenue for the assessment year 2003-04 and gro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nsideration are similar to the facts and circumstances in the assessment year 2002-03. We find that a coordinate bench in their decision dated 9 th October, 2009 in ITA No. 1966/D/09 for the assessment year 2002-03 concluded as under: 12. We have heard the rival submissions and have gone through the material available on record. We find that it has been noted by the learned Commissioner of Income Tax (Appeals) in para no. 3.3 of his order that it was submitted before him that the assessee has claimed an amount of ₹ 56,926,000/- on account of loss on sale of repossessed assets as revenue expenditure. It is also noted that it is the claim of the assessee that the claim of the assessee is nothing but bad debts incurred by the assessee during the course of its normal business operations. Learned Commissioner of Income Tax (Appeals) has decided this issue against the assessee on the basis that this loss is related to write off of repossessed assets and is not related to debts as such. We are of the considered opinion that this loss is allowable to the assessee since the loss has been incurred in normal course of business. Repossession of the asset was taken by the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... case, we do not see any merit in this ground of the departmental appeal. 16. Next issue Ground No. 5 relates to the deletion of addition of ₹ 3,61,02,215/- made by the AO on account of depreciation on computer peripherals. 17. After considering the submissions of both the parties and the material on record, it is noticed that an identical issue had already been adjudicated by this Bench of the Tribunal in assessee s own case in the preceding year i. E. assessment year 2006-07 wherein the relevant findings has been given in para 33 of the order dated 20.02.2015 which read as under: 33. We have considered the submissions of both the parties and have perused the record of the case. We find that Hon ble High Delhi High Court in the case of Citicorp Maruti Finance Ltd. (supra) has held as under: The assessee had also claimed depreciation at the rate of 60% on computers accessories and peripherals purchased by the assessee during this year. The Assessing Officer, however, allowed the depreciation at the rate of 25%. The Commissioner of Income Tax (Appeals) reversed this part of the order of the Assessing Officer holding that on computer acc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al or revenue expenditure. Deferred revenue expenditure denotes expenditure for which a payment has been made or a liability incurred, which is essentially revenue in nature but which for various reasons like quantum and period of expected future benefit etc., is written off over a period of time e. G. expenditure on advertisement, sales promotion etc. Though the nature of such expenditure is revenue, keeping in view the fact that the benefit arising there from are expected to be derived over a period of time, stretching sometimes over several accounting years, the taxpayers have been amortizing the same over the expected time period over which the benefits are likely to accrue there from. Accordingly, only a proportion of such expenditure is amortised in the Profit and Loss Account but an appropriate adjustment is made in the computation of income, claiming the entire as allowable revenue expenditure in terms of provisions of section 37(1) of the Act. The expenditure which is treated as deferred revenue in the books almost in all cases comprises of items, the benefits derived wherefrom are ephemeral and transitory in nature in as much as these are incurred as a part of a continuou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... epreciation allowable thereon as per the prescribed rules and procedures under the Income Tax Act. 25.2 In the instant case, there is no material before us to infer that the aforesaid expenditure resulted in creation of any capital asset, tangible or intangible, and thus, the question of treating the same as capital expenditure does not arise. In fact, the Hon ble Supreme Court itself in Madras Industrial Investment Corporation Limited (supra) while discussing the issue, in the said case, and distinguishing between various situations observed that Ordinarily, revenue expenditure which is incurred wholly and exclusively for the purpose of business must be allowed in its entirety in the year in which it is incurred. It cannot be spread over a number of years even if the assessee has written it of in his books over a period of years. 25.3 Another argument by the ld. DR is the variation and dichotomy between the accounting treatment of such expenditure in the books of account and its claim under the Act. As far as the entries in the books of account are concerned, it is well settled that they do not clinch the issue either way, and are not determ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... any other provision of the Act as was pointed out by Lord Russell in the case of B. S. C. Footwear Ltd. (1970) 77 ITR 857, 860 (CA), the Income Tax Law does not march step by step in the footprints of the accountancy profession. 25.6 In a later decision in CIT Vs Secure Meters Ltd. (2009) TIOL 93, Hon ble Apex Court taking note of their earlier decision in India Cements ltd. (supra) held that expenditure on loan was allowable as revenue expenditure. The Revenue in this case contended that since the debentures were convertible and on conversion, it would add to the capital of the company, the expenditure should also be construed as capital expenditure. The Hon ble Supreme Court rejected this contention and held that the debentures were loans and the object of a loan was not relevant. Accordingly, it was concluded that expenses on issue of debentures, whether convertible or not, is allowable as a deduction in computing the income of the assessee. 25.7 In view of the foregoing, especially when the Revenue have not brought to our notice any contrary decision nor any other material so as to enable us to take a different view in the matter, we have no h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt in books of accounts does not govern the tax treatment, which is governed by the provisions of the Act. As already observed by us in paras 25 to 25.7 while adjudicating ground No. 3 in the appeal of the revenue for the assessment year 2003-04 and ground No. 7 in their appeal for the assessment year 2005-06, the concept of deferred revenue expenditure is essentially an accounting concept and alien to the Act. The relevant provisions of the act recognize only capital or revenue expenditure. Indisputably, the amount claimed by the assessee in these three assessment years is revenue in nature. Deferred revenue expenditure denotes expenditure for which a payment has been made or a liability incurred, which is essentially revenue in nature but which for various reasons like quantum and period of expected future benefit etc., is written off over a period of time e. G. expenditure on advertisement, sales promotion etc. There is no material before us to infer that the aforesaid expenditure resulted in creation of any capital asset, tangible or intangible, and thus, the question of treating the same as capital expenditure does not arise. In fact, the Hon ble Supreme Court itself i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... age PLI of the comparables worked out to 13.43%. The assessee had a return on total cost of 18% during the year ended on 31.03.2007. Accordingly, the fees received by the assessee for software customization and sport services run to its associate enterprises amounting to ₹ 20,97,13,000/- was considered to be at Arm s length. During the transfer pricing proceedings, the TPO asked the assessee to submit transfer pricing study report and other necessary information on the basis of which comparables were debited by the assessee. The TPO rejected 16 comparables used by the assessee out of the total 18 comparables and then proceeded to search for his own comparables. The TPO used 24 new comparables and also included two comparables which were selected by the assessee. The average PLI worked out by the TPO on the basis of 26 (24+2) comparables was 24.39% and the Arm s length price was computed by the TPO at ₹ 22,10,69,639/-. Accordingly, an upward adjustment of ₹ 1,13,56,639/-was made by the TPO u/s 92CA of the Act. The AO made the addition of the aforesaid amount being satisfied and in agreement with the order passed by the TPO. 28. Being aggrieved the assessee ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Computech International Ltd. (Software segment) Persistent Systems Ltd. Karuturi Networks Ltd. (project sales and software development segment) Quintegra Solutions Ltd. R S Software (India) Ltd. R Systems International Ltd. (Seg.) Sasken Communication Technologies Ltd. (Seg.) Tata Elxsi Ltd. (Seg.) Thirdware Solutions Ltd. Wipro Ltd. (Seg.) SIP Technologies Exports Ltd. Mindtree Consulting Ltd. 29. The assessee raised several objections to the use of fresh filters which the ld. CIT(A) summarized in para 10.5 of the impugned order which read as under: Filter Assessee s arguments TPO argume ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nalysis should be base on FAR wherein actual functions performed by the Company should be evaluated rather than be based on financial ratios Companies can have different business models which may not be reflected in wages to sales ratio TNMM method does not differentiate b/w different heads of cost and possibility of applying this ratio will question the appropriateness of this method There may not be uniformity in disclosing employee cost and different companies may disclose it under heads Employee cost is a major cost in this industry and failure to comply with this filter means that the company is outsourcing its major work or is a software products company or a trading company or a company with peculiar economic circumstances Low employees cost means that the co is functionally different Revenue earned by a software development company is generally directly proportional to number of employees Power u/s 133(6) was used to where complete info was not available No comparable has been accepted/rejected merely on this ground 4) Companies with Diminishing revenue filter (revenue less than 30% over last 10 years or at least 3 year ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ails of onsite and offsite revenues for comparables is not available in public domain Any assessee will be engaged in both onsite and offsite revenues composition of which will vary from year to year Taxpayer is mainly an offshore service provider and is difficult to get independent companies which generate revenues only from offshore software development services Offshore margins are more than onshore margins Pricing for the tow is different since in case of offshore projects most of the costs are incurred in India whereas employee costs significantly increases in case of onsite project Onsite companies do not have significant assets since most of the work is carried outside India on customer site Co s generating more than 75% of export revenues from onsite companies working outside India having their own geographical markets, cost of labour etc. 30. The assessee objected to the rejection of his own comparable by the TPO and explained the functions performed by it in the following words: The appellant is a non banking finance company primarily engaged in the business of providing finance to customers for auto, sales finan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed by the appellant. TPO has also pointed out that till last assessment year the appellant itself was using Infosys as a comparable company in its set. Therefore, I hold that there is no merit in the argument of the appellant and this company should be chosen as a comparable. Megasoft Ltd. ( Megasoft ) : Appellant had made the following submission about this comparable: Without prejudice to the argument of the appellant on collection of information under section 133(6) of the Act, the appellant proceeds to submit as under: Functionally different: The appellant submits before Your Honours that Megasoft is a functionally different company from the appellant. According to the reply submitted by Mcgasoft Ltd. to the Revenue quoted by the TPO in his order, Megasoft is into product development and providing specialized application services through its two divisions namely Xius-bcqi division and BlueAlly Division. Please find below the extract of the reply submitted by Megasoft (page no 702 of the paper book): Xius-bcgi division 1. The Xius-bcgi division is a total telecom division whose main focus would be to invent, market and manage cutting ed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are embedded with customized software, sale of licenses with no. of users, revenue sharing in mobile roaming usage, upfront fee or product installation, annual maintenance income, sharing of prepaid billing solutions. Hence it is practical difficult to state number of licenses sold and revenues earned from this division. Each invoice varies from customer to customer, strictly prices are not comparable and not attributed to particular head of revenue. (copies of invoices are included) 5. BlueAlly Division BlueAlly services portfolio comprises of application development and application management services and concept - to - market partnerships. Application Development Services: BlueAlly helps customers optimize their IT investments by advising on how best to rationalize their application portfolio. With significant experience working across various platforms and technologies, including integration of multiple technology environments. Application Management Services: Designed to address customers needs for reliability, high availability, and evolving functionality of their existing business applications. Because an effective and fully utilized enterprise a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nditure or perform any brand building exercise. Restructuring/ Extra-ordinary business circumstances: As per the page no 3 of the annual report of Megasoft, the Company has undergone restructuring during the relevant FY. Following extract from company s annual report supports the same: The financial results of both standalone and consolidated for the previous financial year include the business performance of VisualSoft Technologies Limited w. E. F. 1 October 2006, consequent to the amalgamation. Hence, the results are not comparable. Further, the Company has also acquired US Based Boston Communications Group Inc (bcgi) in August 2007. The above mentioned acquisitions have resulted in high profit margin for the Company. Accordingly, Megasoft cannot be considered as comparable to the appellant due to presence of peculiar economic circumstances. Incorrect computation of PLI - Without prejudice to the above arguments, it is submitted that PLI computed by the TPO is incorrect on account of the following reasons: As per the TPO s order (page no 705 of the paper book), revenue of both XIUS- bcgi division and BlueALLY division has been taken for comp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The OP/TC of OITL has been worked out at -5.96%. It is respectfully submitted that just by the reason that OITL is a loss making company, the same cannot be excluded from the set of comparables. In this regard, appellant would like to place reliance on the recent decision of Delhi Tribunal in the case of Yum Restaurants India Private Limited (ITA No. 5122/Del/2010) (enclosed as Annexure 5) wherein it has been held that loss making companies cannot be rejected as comparables simply on the ground of losses. Following observation has been made by ITAT: We have no hesitation in observing that merely a company is showing losses would not loose its status of comparable if other criteria depicted status of comparables. Declaration of loss is an incidental of business which is at par with the profit. Similar view has also been taken by Delhi Tribunal in the case of Sony Indio (P) Limited 114 ITD 448 where the Tribunal observed as follows: It is no doubt true that loss and competition are normal incident of business and merely on above factors, exclusion may not be justified. Accordingly the appellant prays that the above company should be included in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rables as selected by the TPO should be retained in the set, with this observation the working capital adjustment as given by the TPO was upheld. The ld. CIT(A) also held that if the mean margin of the 26 comparables so calculated falls within 5% of the range, then, the addition made to the international transaction should be deleted. 36. The ld. DR strongly supported the order of the TPO/AO and further submitted that the AO accepted whatever data was provided by the assessee. He further submitted that the ld. CIT(A) was not justified in directing the TPO/AO to exclude the Mega Soft Ltd. because the assessee had not provided any data to substantiate that the said comparable was functionally different from the assessee. He further submitted that the ld. CIT(A) was also not justified in including the Orient Information Technology Ltd. particularly when this company was making loss and was a diminishing revenue company. The reliance was placed on the following case laws: Sony India Pvt. Ltd. Vs DCIT 114 ITD 448 (Del.) 37. In his rival submissions the ld. Counsel for the assessee reiterated the submissions made before the authorities below and further submitt ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee did not have. The said company also acquired US based Boston Communications Group Inc. in August 2007, which also resulted in high profit margin of the said company. Therefore, the ld. CIT(A) rightly held that Mega Soft Ltd. to be excluded from the set of comparables. We, therefore, considering the totality of the facts as discussed hereinabove are of the view that the ld. CIT(A) rightly directed the AO to exclude the Mega Soft Ltd. and include the Orient Information Technology Ltd. in the comparables and worked out the Arm s lengh price and if it falls within the range of 5% of the range then no addition is to be made. We do not see any infirmity in the impugned order of the ld. CIT(A). 40. In ITA No. 6305/Del/2012 for the assessment year 2008-09, following ground have been raised: 1. The Ld. CIT(A) has erred on facts and in law in deleting the addition on account of loan acquisition cost amounting to ₹ 1,24,84,98,967/- ignoring the facts and judicial decisions the loan acquisition fee expenses is spread over the period of three years according 1/3 rd of the total loan acquisition fee is allowed in current year rest being is allowable in the ne ..... 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