{"id":21094,"date":"2019-09-14T12:09:34","date_gmt":"2019-09-14T06:39:34","guid":{"rendered":"http:\/\/itatonline.org\/archives\/?p=21094"},"modified":"2019-09-14T12:11:40","modified_gmt":"2019-09-14T06:41:40","slug":"fomento-resorts-hotels-ltd-vs-acit-bombay-high-court-goa-bench-s-147-148-it-is-mandatory-for-the-ao-to-follow-the-procedure-laid-down-in-gkn-driveshafts-259-itr-19-sc-and-to-pass-a-separate-order","status":"publish","type":"post","link":"https:\/\/itatonline.org\/archives\/fomento-resorts-hotels-ltd-vs-acit-bombay-high-court-goa-bench-s-147-148-it-is-mandatory-for-the-ao-to-follow-the-procedure-laid-down-in-gkn-driveshafts-259-itr-19-sc-and-to-pass-a-separate-order\/","title":{"rendered":"Fomento Resorts & Hotels Ltd vs. ACIT (Bombay High Court) (Goa Bench)"},"content":{"rendered":"

1 txa63-07dt. 30-08-19
\nSantosh
\nIN THE HIGH COURT OF BOMBAY AT GOA
\nTAX APPEAL NO.63 OF 2007
\nFomento Resorts & Hotels Ltd.,
\na Company incorporated under the
\nprovisions of the Companies Act, 1956
\nand having its registered office at
\nCidade de Goa Beach Resort,
\nVainguinim Beach, Goa-493 004,
\nthrough its Secretary I. B. Muchandi. \u2026. Appellant.
\nVersus
\nThe Assistant Commissioner of
\nIncome-tax, Central Circle,
\nPanjim having his address at
\nPanjim, Goa. \u2026. Respondent.
\nMr. Rafiq Dada, Senior Advocate with Mr. Nishant Thakkar, Ms.
\nJasmin Amalsadvala and Ms. Vinita Palyekar, Advocates for the
\nAppellant.
\nMs. Susan Linhares, Standing Counsel for the Respondent.
\nCoram : M.S. Sonak &
\nNutan D. Sardessai, JJ.
\nReserved on : 6th August, 2019.
\nPronounced on : 30th August, 2019.
\nJ U D G M E N T : (Per M.S. SONAK, J.)
\nHeard Mr. Rafiq Dada, learned Senior Advocate with Mr.
\nN. Thakkar and Ms. V. Palyekar for Appellant and Ms. Susan
\n2 txa63-07dt. 30-08-19
\nLinhares, Standing Counsel for the Respondent.
\n2. This Appeal was admitted on 20th November, 2007 on the
\nfollowing substantial questions of law :
\n(a) Whether on the facts and in the circumstances of the
\ncase, the Income-Tax Appellate Tribunal ought to have held
\nthat since the respondent did not furnish to the appellant
\nthe reasons recorded for reopening of the assessment for the
\nassessment year 1997-98 and did not comply with the
\nmandatory preconditions laid down by the Hon’ble
\nSupreme Court in GKN Driveshaft vs. ITO 259 ITR page
\n19, the reassessment order was bad in law as being opposed
\nto the principles of natural justice ?
\n(b) Whether on the facts and in the circumstances of the
\ncase the Income-tax Appellate Tribunal was justified in
\nholding that chargeable expenditure had to be computed
\nwith reference to the unit of residential accommodation in
\nthe hotel and not with reference to the number of persons
\noccupying the said unit of accommodation ?
\n3. The brief facts in which the aforesaid substantial questions
\nof law fall for determination, are set out hereafter :
\n(A) The Appellant filed a return under the provisions of the
\nExpenditure Tax Act, 1987 (said Act), showing chargeable
\nexpenditure at rupees Nil on 12.8.1998. The Respondent, by notice
\ndated 13.3.2003, by invoking the provisions in Section 11 of the said
\nAct, sought to reopen the assessment.
\n3 txa63-07dt. 30-08-19
\n(B) On the reverse of the notice dated 13.3.2003, the following
\nendorsement finds place :
\n\u201cReasons for Reopening :- In view of the Himachal High
\nCourt decision in the case of H.P. Tourism Development
\nCorporation (238 ITR 38), the expenditure has escaped
\nassessment.\u201d
\n(C) The Appellant, vide letter dated 14.4.2003, applied for furnish of
\nreasons recorded for reopening of the assessment and also lodged
\nobjections to the assumption of the jurisdiction.
\n(D) The Appellant, without prejudice also filed their reply on
\n16.4.2003 in response to the notice under Section 11 of the said Act
\ndated 13.3.2003.
\n(E) Since the Appellants heard nothing further in the matter, the
\nAppellants by their letter dated 25.3.2004, once again called upon
\nthe Assessing Officer to dispose of their objections for reopening of
\nthe assessment, prior to commencement of the assessment for the
\nAssessment Year 1997-98.
\n(F) The Assessing Officer, without making any order disposing of the
\nobjections filed by the Appellants, proceeded to make an assessment
\norder dated 26th March, 2004, bringing to charge taxable
\nexpenditure of \u20b9 10,22,73,987, relying upon the decision of the
\nHimachal Pradesh Tourism Development Corporation vs.
\n4 txa63-07dt. 30-08-19
\nUnion of India and ors.1. The Assessing Officer, in his order dated
\n26th March, 2004, sought to dispose of the written objections raised
\nby the Appellants to the reopening of the assessment.
\n(G) The Appellants, aggrieved by the Assessing Officer\u2019s order dated
\n26th March, 2004, appealed to the Commissioner of Income-tax
\n(Appeals) \u2013VI. In the Appeal, the Appellants specifically urged that
\nthe Assessing Officer had breached the mandatory conditions laid
\ndown by the Hon\u2019ble Supreme Court in the cases of GKN
\nDriveshafts (India) Ltd. vs. Income Tax Officer & ors. 2 on the
\nissue of reopening of assessment.
\n(H) The Commissioner (Appeals), vide order dated 30th November,
\n2004, dismissed the Appeal, holding that the assumption of the
\njurisdiction by the Assessing Officer under Section 11 of the said Act,
\nwas valid.
\n(I)The Appellants, aggrieved by the Judgment and Order dated 30th
\nNovember, 2004, preferred an appeal to the Income Tax Appellate
\nTribunal (ITAT). However, by Judgment and Order dated 4th April,
\n2005, the ITAT was pleased to dismiss the Appellant\u2019s Appeal.
\n(J) Hence the present Appeal, which came to be admitted on 20th
\nNovember, 2007 on the aforesaid substantial questions of law.
\n1 238 ITR 38
\n2 259 ITR 19(SC)
\n5 txa63-07dt. 30-08-19
\n4. Mr. Rafiq Dada, learned Senior Advocate for the
\nAppellants, submitted that in case the first substantial question of law
\nis answered in favour of the Appellant and against the Respondent-
\nRevenue, then, there will be no necessity to advert to the second
\nsubstantial question of law. This position was not seriously disputed
\nby Ms. Linhares, learned Standing Counsel for the Respondent.
\nEven, otherwise, the first substantial question of law relates to
\nassumption of jurisdiction by the Assessing Officer under Section 11
\nof the said Act. If this question is answered in favour of the
\nAppellant-Assessee and against the Respondent-Revenue, then, it will
\nhave to be held that the assumption of jurisdiction by the Assessing
\nOfficer under Section 11 of the said Act, was ultra vires the
\nprovisions of Section 11 of the said Act. Any decision on the second
\nsubstantial question of law, in that eventuality, will be quite
\nredundant and unnecessary.
\n5. Mr. Dada, the learned Senior Advocate for the Appellants
\nsubmits that the decision of the Supreme Court in GKN
\nDriveshafts (India) Ltd . (supra) is quite clear, inasmuch as it
\nprovides that the Assessing Officer is bound to furnish the Assessee,
\nreasons for reopening of the assessment, on demand. Further, the
\nAssessee is entitled to raise objections and the Assessing Officer is
\n6 txa63-07dt. 30-08-19
\nbound to dispose of such objections by passing a speaking order,
\nbefore he proceed with reopening of the assessment. Mr. Dada
\nsubmits that this decision was applied by the Respondent to the case
\nof this very Appellants for the Assessment Year 1995-96. Such
\napplication was expressly upheld by this Court, as well as by the
\nHon\u2019ble Apex Court in the case of this very Appellant. Mr. Dada
\nsubmits that the Assessing Officer, without disposing of the
\nobjections raised by the Appellants, could not have proceeded to
\nmake the assessment, which has been done in the present case. He
\nsubmits that such a course of action has been expressly held as
\nimpermissible by this Court in the cases of Bayer Material Science
\n(P) Ltd. vs. Deputy Commissioner of Income-tax-10(3) 3, and
\nKSS Petron Private Ltd. vs. The Assistant Commissioner ofIncome Tax Circle<\/a> 10(2)4 . For all these reasons, Mr. Dada submits
\nthat the first substantial question of law is required to be answered in
\nfavour of the Appellant-Assessee and against the Respondent-
\nRevenue.
\n6. Mr. Dada adopted the submissions made by him in Tax
\nAppeal No.32\/2006 and other connected Appeals, in so far as the
\nsecond substantial question of law is concerned. However, he submits
\n3 382 ITR 333 (Bom.)
\n4 ITXA 224 of 2014
\n7 txa63-07dt. 30-08-19
\nthat should the first substantial question of law be answered in favour
\nof the Appellant, then, at least. in this appeal, there is no necessity of
\nadverting to the second substantial question of law.
\n7. Ms. Linhares, learned Standing Counsel for the Respondent
\nsubmitted that the decision of the Hon\u2019ble Supreme Court in the case
\nof GKN Driveshafts (India) Ltd. (supra), as well as the said two
\ndecisions relied upon by Mr. Dada relate to the provisions of the
\nIncome Tax Act. She submits that in the present case, we are
\nconcerned with the provisions of the Expenditure Act. She submits
\nthat the rulings cited, therefore, are not applicable or, in any case, are
\ninapplicable with all their vigour. She submits that along with the
\nnotice dated 13th March, 2003, the Assessing Officer had furnished
\nreasons to the Assessee and, therefore, there was no question of
\nfurnishing any further reasons to the Assessee. She submits that in the
\nassessment order dated 26th March, 2004, the Assessing Officer has
\ndealt with and disposed of the objections raised by the Appellant to
\nthe reopening of the assessment. She, therefore, submits that without
\nprejudice to the applicability of the decisions cited by Mr. Dada,
\nthere is substantial compliance.
\n8. Ms. Linhares also adopts the submissions made by her in
\nTax Appeal No.32\/2006 and other connected Appeals, in so far as
\n8 txa63-07dt. 30-08-19
\nthe second substantial question of law in this Appeal, is concerned.
\nFor these reasons, Ms. Linhares submits that this Appeal is liable to
\nbe dismissed.
\n9. Rival contentions now fall for determination.
\n10. As noted by us above, should the first substantial question
\nof law be answered in favour of the Appellant-Assessee, and against
\nthe Respondent-Revenue, then, there will be no necessity to advert
\nto the second substantial question of law framed by us in our order
\ndated 20th November, 2007.
\n11. In this case, the Assessing Officer, vide notice dated 13th
\nMarch, 2003, sought to reopen the assessment by invoking the
\nprovisions of Section 11 of the said Act. At the reverse of this notice,
\nthe Assessing Office, had stated the reason for reopening.
\nAccordingly, it cannot be said that no reasons were furnished to the
\nAppellant for reopening of the assessment or that there is breach of
\nthe law laid down by the Hon\u2019ble Apex Court in GKN Driveshafts
\n(India) Ltd. (supra), at least, in so far as requirement of furnishing
\nof the reasons for reopening of the assessment is concerned. To that
\nextent, therefore, we are unable to agree with the contention of Mr.
\nDada that this is a matter where the Assessing Officer failed to
\n9 txa63-07dt. 30-08-19
\nfurnish the reasons for reopening of assessment whilst invoking the
\nprovisions of Section 11 of the said Act.
\n12. Hon\u2019ble Supreme Court in GKN Driveshafts (India)
\nLtd. (supra) has, however, further held that once reasons are
\nfurnished, the Assessee is entitled to lodge his objections and the
\nAssessing Officer is duty bound to dispose of such objections, by
\npassing a speaking order.
\n13. In the present case, the Appellants did lodge their objections
\nvide letter dated 14th April, 2003. By a further letter dated 25th
\nMarch, 2004, the Appellants requested the Assessing Officer to
\ndispose of such objections by passing a speaking order before
\nproceeding with the reassessment in respect of the Assessment Year
\n1997-98. However, the Assessing Officer, without proceeding to
\ndispose of the objections raised by the Appellants by passing a
\nspeaking order, straight away proceeded to make the assessment order
\ndated 26th March, 2004, bringing to charge taxable expenditure on
\n\u20b910,22,73,987\/-. The assessment order dated 26th March, 2004, no
\ndoubt, deals with the objections raised by the Appellant and purports
\nto dispose of the same. Ms. Linhares contends that this is a sufficient
\ncompliance with the procedure set out in GKN Driveshafts (India)
\n10 txa63-07dt. 30-08-19
\nLtd. (supra), assuming that the same is at all applicable to the
\nproceedings under the said Act. Mr. Dada, however, submits that
\nsuch disposal in the assessment order itself does not constitute the
\ncompliance with the mandatory conditions prescribed by the Hon\u2019ble
\nSupreme Court in GKN Driveshafts (India) Ltd. (supra). In
\nsupport, as noted earlier, Mr. Dada relies upon Bayer Material
\nScience (P) Ltd. (supra) and KSS Petron Private Ltd. (supra) .
\n14. The contention of Ms. Linhares that the decisions relied
\nupon by Mr. Dada relate to the provisions of the Income Tax Act
\nand, therefore, are not applicable to the proceedings under the
\nExpenditure Tax Act, cannot be accepted. In the first place, the
\nprovisions relating to reopening of assessment are almost pari materia.
\nSecondly, in so far as Assessment Year 1995-96 is concerned, the
\nRespondent applied the very same ruling in GKN Driveshafts
\n(India) Ltd. (supra) to hold that the notice of reopening of
\nassessment was ultra vires Section 11 of the said Act. This view, in the
\nspecific context of the said Act and incidentally in the specific
\ncontext of this very Appellant, was upheld not only by this Court,
\nbut also by the Hon\u2019ble Supreme Court. This was in ETA No.1 and
\n5\/PANJ\/01 decided by the Tribunal on 4.4.2006.
\n11 txa63-07dt. 30-08-19
\n15. The aforesaid decision of the ITAT was appealed by the
\nRespondent vide Tax Appeal No.71\/2006. This appeal was dismissed
\nby this Court vide order dated 27th November, 2006, which reads
\nthus :
\n\u201c Heard the learned Counsel on behalf of the parties.
\nThis appeal is filed against the Order dated 4-4-2006 of
\nthe ITAT wherein in para 7 the learned ITAT has come to
\nthe conclusion that the Assessing Officer is required to give
\nreasons, when asked for by the Assessee. Giving of reasons
\nhas got to be considered as implicit in Section 11 of the
\nExpenditure Tax Act, 1987. It is now well settled that
\ngiving reasons in support of an order is part of complying
\nwith the principles of natural justice.
\nIn the light of that, no fault could be found with the
\norder of the learned ITAT and as such no substantial
\nquestion of law arises as well.
\nAppeal dismissed.\u201d
\n16. The Respondent, instituted a Special Leave to Appeal
\n(Civil) No.5711\/2007 which was, however, dismissed by the Hon\u2019ble
\nApex Court vide order dated 16\/7\/2007, by observing that there were
\nno merits.
\n17. Accordingly, for the aforesaid reasons, we are unable to
\naccept Ms. Linhares\u2019s contention based upon the any alleged variance
\nbetween the provisions of the said Act and the provisions of the
\nIncome Tax Act, in so far as applicability of the principles in GKN
\n12 txa63-07dt. 30-08-19
\nDriveshafts (India) Ltd. (supra) is concerned.
\n18. The moot question is, therefore, the disposal of the
\nobjections by the Assessing Officer in his assessment order dated
\n26th March, 2004 constitutes sufficient compliance with the
\nprocedure prescribed by the Hon\u2019ble Supreme Court in the case of
\nGKN Driveshafts (India) Ltd. (supra) or, whether it was necessary
\nfor the Assessing Officer to have first disposed of the Appellant\u2019s
\nobjections by passing a speaking order and only upon
\ncommunication of the same to the Appellants, proceeded to reopen
\nthe assessment for the Assessment Year 1997-98.
\n19. Virtually, an identical issue arose in the cases of Bayer
\nMaterial Science (P) Ltd. (supra) and KSS Petron Private Ltd.
\n(supra) before the Division Benches of our High Court at Bombay.
\n20 . In Bayer Material Science (P) Ltd. (supra), by a notice
\ndated 6\/2\/2013, the Revenue sought to reopen the assessment in the
\nyear 2007-08. The Assessee filed a revised return of income and
\nsought for reasons recorded in support of the notice dated 6.2.2013.
\nThe reasons were furnished only on 19.3.2015. The Assessee lodged
\nobjections to the reasons on 25th March, 2015. The Assessing
\nOfficer, without disposing of the Petitioner\u2019s objections, made a draft
\n13 txa63-07dt. 30-08-19
\nassessment order dated 30th March, 2015, since this was a matter
\ninvolving transfer pricing. In such circumstances, the Division Bench
\nof this Court, set aside the assessment order by observing that the
\nCourt was unable to understand how the Assessing Officer could, at
\nall, exercise the jurisdiction and enter upon an inquiry on the
\nreopening notice before disposing of the objections on the reasons
\nfurnished to the Assessee. This Court held that the proceedings
\ninitiated by the Transfer Pricing Officer (TPO), on the basis of such a
\ndraft assessment order, were without jurisdiction and quashed the
\nsame.
\n21. Similarly, in the case of KSS Petron Private Ltd. (supra),
\nthis Court was concerned with the following substantial question of
\nlaw :
\n\u201cWhether on the facts and circumstances of the case and in
\nlaw, the Tribunal was justified in restoring the issue to the
\nAssessing Officer after having quashed\/set aside the order
\ndated 14th December, 2009 passed by the Assessing Officer
\nwithout having disposed of the objections filed by the
\nappellant to the reasons recorded in support of the reopening
\nNotice dated 28th March, 2008 ?\u201d
\n22. In the aforesaid case, the Assessing Officer had purported
\nto dispose of the objections to the reasons in the assessment order,
\nconsequent upon reopening of the assessment. This Court, however,
\n14 txa63-07dt. 30-08-19
\nheld that the proceedings for reopening of assessment prior to
\ndisposing of the Asessee\u2019s objections by passing a speaking order, was
\nan exercise in excess of jurisdiction.
\n23. KSS Petron Private Ltd. (supra), this is what the Division
\nBench has observed at paragraphs 7 and 8 of the Judgment :
\n\u201c7. On further Appeal, the Tribunal passed the
\nimpugned order. By the impugned order it held that the
\nAssessing Officer was not justified in finalizing the
\nAssessment, without having first disposed of the objections
\nof the appellant. This impugned order holds the Assessing
\nOfficer is obliged to do in terms of the Apex Court’s
\ndecision in GKN Driveshafts (India) Ltd., v\/s. ITO 259
\nITR 19. In the aforesaid circumstances, the order of the
\nCIT(A) and the Assessing Officer were quashed and set
\naside. However, after having set aside the orders, it restored
\nthe Assessment to the Assessing Officer to pass fresh order
\nafter disposing of the objections to reopening notice dated
\n28th March, 2008, in accordance with law.
\n8. We note that once the impugned order finds the
\nAssessment Order is without jurisdiction as the law laid
\ndown by the Apex Court in GKN Driveshafts (supra) has
\nnot been followed, then there is no reason to restore the
\nissue to the Assessing Officer to pass a further\/fresh order.
\nIf this is permitted, it would give a licence to the Assessing
\nOfficer to pass orders on reopening notice, without
\njurisdiction (without compliance of the law in accordance
\nwith the procedure), yet the only consequence, would be
\nthat in appeal, it would be restored to the Assessing Officer
\nfor fresh adjudication after following the due procedure.
\n15 txa63-07dt. 30-08-19
\nThis would lead to unnecessary harassment of the Assessee
\nby reviving stale\/ old matters.\u201d
\n24. According to us, the rulings in Bayer Material Science (P)
\nLtd. (supra) and KSS Petron Private Ltd. (supra) afford a complete
\nanswer to the contentions raised by Ms. Linhares in defence of the
\nimpugned order.
\n25. Since, in the present case, the Assessing Officer has
\npurported to assume the jurisdiction for reopening of the assessment,
\nwithout having first disposed of the Assessee\u2019s objections to the
\nreasons by passing a speaking order, following the law laid down in
\nGKN Driveshafts (India) Ltd. (supra), Bayer Material Science
\n(P) Ltd. (supra) and KSS Petron Private Ltd. (supra), we are
\nconstrained to hold that such assumption of jurisdiction by the
\nAssessing Officer was ultra vires Section 11 of the said Act. The first
\nsubstantial question of law will, accordingly, have to be answered in
\nfavour of the Appellant and against the Respondent-Revenue.
\n26. As noted earlier, in view of the aforesaid, there is no
\nnecessity to advert to the second substantial question of law, at least,
\nin so far as this Appeal is concerned. The Appeal is, therefore, allowed
\nand the impugned orders dated 26th March, 2004 made by the
\n16 txa63-07dt. 30-08-19
\nAssessing Officer, 30th November, 2004 made by the Commissioner
\n(Appeals) and 12th January, 2007 made by the ITAT are set aside on
\nthe ground of want of compliance with jurisdictional parameters by
\nthe Assessing Officer, and without going into the second substantial
\nquestion of law framed in this Appeal. Accordingly, we clarify that
\nthe second substantial question of law, raised in this Appeal, is not to
\nbe treated as decided in this Appeal, one way or the other.
\n27. The Appeal is allowed in the aforesaid terms. There shall be
\nno order as to costs.
\nNutan D. Sardessai, J. M.S. Sonak, J.<\/p>\n","protected":false},"excerpt":{"rendered":"

The moot question is, therefore, the disposal of the objections by the Assessing Officer in his assessment order dated 26th March, 2004 constitutes sufficient compliance with the procedure prescribed by the Hon\u2019ble Supreme Court in the case of GKN Driveshafts (India) Ltd. (supra) or, whether it was necessary for the Assessing Officer to have first disposed of the Appellant\u2019s objections by passing a speaking order and only upon communication of the same to the Appellants, proceeded to reopen the assessment<\/p>\n

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