prpri Section 147: Assessee cannot be put to mercies of careless, casual, arbitrary or whimsical exercise of power Section 147: Assessee cannot be put to mercies of careless, casual, arbitrary or whimsical exercise of power

Case Law Details

Case Name : Smt. Simar Kaur Vs ACIT (ITAT Chandigarh)
Appeal Number : ITA No. 220/CHD/2019
Date of Judgement/Order : 25/05/2021
Related Assessment Year : 2010-11

Simar Kaur Vs ACIT (ITAT Chandigarh)

It is seen that the assessee has consistently maintained its challenge that notice was not issued as it has not been served. The tax authorities have rejected the challenge holding that non-receipt is not equivalent to non-service.

It is seen that though the challenge is recorded the wording in its rejection has been remained ambivalent as no specific finding is found to have been given holding that the notice was issued on a specific date. Nor is there any reference addressing the mode and manner of its issuance nor the fact that it was issued at the correct address. In order to hold that the notice was issued, these above facts need to be recorded and available on record so as to enable an adjudicating authority to conclusively uphold the finding as otherwise sans facts the conclusion is open to the challenge of being arbitrary dehors facts and hence non-maintainable.

Thus, though the dismissal of the ground in the manner worded in the face of the challenge does not inspire much confidence in its correctness, however, even otherwise, I find that the assessee has a good case on the legal challenge posed as well as on merits. No doubt mention of the full investment value finds a mention in the “reason to believe”, the fact remains that addition has been made proportionate to the assessee’s share. This fact by itself may not lead generally to the conclusion that the re-opening was mechanical.

However, in the facts of the present case, when the Sale Deed is taken into consideration, it is clearly evident that it spells out the fact that only part consideration was moving from the assessee and thus if this bare document itself had been seen before the formation of the belief by the A.O. then while recording the reasons the AO would not have recorded the entire consideration as assessee’s contribution and would have noticed that there were other contributors also. The fact that this document was properly seen at the assessment stage as ultimately instead of Rs. 63.51 lakhs was limited to Rs. 28,03,753/- i.e. the assessee’s share. No doubt the assessee was not a regular tax payer and thus, no return could be consulted by the Assessing Officer while exercising the powers of re-opening. However, the fact remains that it was incumbent on him to at least check the facts recorded in the Sale Deed carefully ascertaining the extent of the assessee’s contribution. Since the facts set out in the Sale Deed cognizance of which was taken by the Assessing Officer himself while making the addition were un-disputably clear as is evident from Paper Book pages 10, 11, 11A and 12 the conclusion that admittedly its proper consideration escaped the notice of not only the A.O. but the approving authority also is clearly evident from record. Thus not finding fault in the manner of the specific words recorded in the order to grant approval, which has been the crux of ld AR’s argument the objection is sustained on the fact that no care or attention evidently was taken to consider the bare preliminary facts itself and the power was exercised mechanically without examining the record.

An authority vested with the onerous powers of re-opening u/s 147 and granting of approval is expected to exercise its power consciously, carefully and with full awareness. The public at large cannot be put to the mercies of careless, casual, arbitrary or whimsical exercise of power. The order deserves to be quashed on this count itself. Ordered accordingly.

FULL TEXT OF THE ITAT JUDGEMENT

The present appeal has been filed by the assessee against the order dated 16.01.2019 of CIT(A) Karnal pertaining to 2010­11 assessment year on the following grounds:

1. That the Ld. CIT(A) has erred in confirming the action of the Assessing Officer with regard to reopening of the case u/s 148 and also on merits.

2. That the Ld. CIT(A) has erred in holding the proceedings u/s 148 as valid even though there were no reasons to believe that the income of the assessee as escaped assessment under such section to the tune of Rs. 63.51 lacs.

3. That the Ld. CIT(A) has erred in holding the proceedings u/s 148 as valid even though the approval for initiating proceedings under section 147 given by the PCIT/JCIT-Karnal has been given in mechanical manner without application of mind.

4. That the Id. CIT(A) has erred in holding that the notice u/s 148 was legally valid and has failed to consider the fact that the notice u/s 148 was never served upon the assessee and was returned back to the Department unserved on 10th of April 2017 and, as such, the proceedings are void-ab-initio

5. That the notice u/s 148 of the Act has not been served as per section 282 of the Income Tax Act read with CPC procedure.

6. Notwithstanding the above said ground of appeal, the Ld. CIT (A) has erred in confirming the addition of Rs. 28,60,000/- as unexplained investment by not considering our submissions properly.

7. That the Appellant craves leave to add or amend the grounds of appeal before the appeal is finally heard or disposed off

2. Inviting attention to grounds 1 to 5 raised herein above, it was his submission that by way of these grounds, the assessee has challenged the jurisdiction and vide ground No. 6 the challenge is posed on the merits of the addition made.

3. Addressing the respective orders of the tax authorities, the ld. AR challenged the order on the ground that the order for want of jurisdiction deserves to be quashed as notice to the assessee was never issued by the Assessing Officer. This challenge, it was submitted remains un-assailed on record. Jurisdiction was also challenged on the grounds of being arbitrary as it was exercised mechanically. It was submitted this fact was evident from the record itself as no effort, as a matter of record was made to see the actual proportionate share of the assessee’s contribution and the reasons recorded would show that entire hundred percent investment in the property was wrongly considered to have been made by the assessee. This mistake and incorrect fact recorded in the reasons recorded, it was submitted, had been corrected by the Assessing Officer himself at the assessment stage as ultimately addition was made to the proportion relatable to the assessee’s share. The said addition is also challenged on merits. However, reverting to the jurisdictional challenge, it was argued that the approval was mechanically given by the approving authority. On the basis of these arguments relying on judicial precedent available it was his prayer that the order of A.O. may be quashed.

3.1 Notwithstanding the above arguments, it was his submission that the impugned order deserves to be set aside on merits also. Referring to the record it was submitted, that the assessee’s submissions and evidences remained ignored. The order was assailed stating that no effort even to discuss them was made by the Appellate Authority. Attention was invited to the fact that an explanation all along was offered without prejudice to the primary objection and this was evident from the discussion thereof in the assessment order, itself though the discussion was incomplete. For the said purposes attention was invited to the documents on record. It was submitted that apart from the synopsis which has summed up the legal argument and the case law being relied upon, reliance was placed on Paper Book No. 1. The Paper Book contains the documents running from page 1 upto page 49; and Paper Book No. 2 running from 50 to 63 and case laws Paper Book running upto 154 pages in total. It was submitted, that the documents contained in Paper Book-1 are certified copies of record obtained from the office of the AO.

4. Relying on the synopsis and reading through the background of the case and the issues involved, facts and records available were highlighted. For ready reference, para 1 to 4 of the synopsis being relied upon is extracted hereunder:

1. The case of the Assessee was reopened by issue of notice u/ sec 148 of the Act.

2. Such case was reopened based on information about a property purchased by the appellant to the tune of Rs. 63.51 lacs and the Assessing Officer (‘AO’) framed the Assessment assessing the income at Rs. 28.04 lacs for the share of the appellant in such property.

The assessment was framed ignoring the facts that: The notice for attaining jurisdiction i.e. notice u/ sec 148 was never served on the assessee and

3. The submissions explaining the sources of such purchase of property which were duly brought on record by the assessee for Rs. 27.81 lacs being 42.78% of Rs. 65.41 of whole property transaction value (i.e. Rs. 63.51 lacs Transaction value & Rs. 1.9 lacs Stamp Duty)). [Reasons at Page-1 Paperbook (‘PB’)].

4. The assessee filed an appeal before the CIT(A), Karnal, and duly explained that the proceedings itself were void in case of the appellant;

in the absence of valid service of notice u/ s 148 &

in the absence of valid reasons to believe for reopening the case u/s 148 &

in the absence of valid satisfaction of the Pr. CIT, Karnal for reopening the case u/s 148

besides the fact that the sources of purchase of property were duly submitted to the AO,

which were ignored by the Worthy CIT(A) and the case was decided against the facts and circumstances of the case.

5. The legal challenge addressed vide ground No. 1 to 5 as set out in page 2 of the synopsis was referred to so as to set out the following facts :

A. Issue of Notice u/s 148 of the Act for re-assessment proceedings u/sec 147 of the Act being Void Ab initio, being based on notice which was never served on the assessee and

B. Notice u/s 148 issued without any valid ‘reasons to believe’, which is clearly evident from the fact that the income alleged as escaped in the reasons being Rs. 63.51 lacs of purchase consideration was itself revised to Rs.28.04 lacs at the time of assessment finalization.

C. Issue of reopening of the assessment based on mechanical satisfaction of the Pr. CIT, Karnal without application of mind

6. The reasoning of the AO and of the First Appellate Authority upholding the AO was assailed on the following grounds:

At the outset, it is submitted the notice u/s 148 was never served on the assessee and therefore the jurisdiction for reassessment assumed on the basis of such notice issued u/s 148 of the Act is bad in law and must be restored to nullity.

Moreover, during the assessment proceedings, when the assessee received a notice u/s 142(1) of the Act, he:

i. attended the assessment proceedings though his authorized representative;

ii. brought out the issue of non-service of notice us 148 of the act to the AO;

iii. filed a return u.s 148 under protest, without waiving off his rights to challenge the jurisdictional wrongly assumed by the assessee in his case.

  • Non-Service of notice u/s 148

On inspection of the file, it was discovered that the basis of assuming jurisdiction in case of the assessee being the notice u/s 148 was never served on the assessee and as such the notices issued subsequent to the notice u/s 148 have no sanctity left as the proceedings themselves have become null and void. Copy of such notice u/s 148 issued to the assessee, which was duly returned back to the department unserved and which was never served on the assessee till date is attached at Pages 4-5 of the PB.

It is also submitted that once the assessee, duly challenged the non-service of the notice issued u/s 148 during the assessment proceedings itself, the onus of having served the said notice u/s 148 on the assessee lied with the AO only.

Also, no affixture order was made in order to ensure service as per the procedure laid down under in Section 282 (1) of the Act read with Order V Rule 12 CPC and Order III Rule 6 CPC for service of notice and thus even on this basis the service of notice was not properly made.

The above clearly shows that no action was taken by the AO to ensure the service of such notice and no such proof of service was brought on record by the Ld. AO.

Thus, the action of the AO in re-assessing the income of the assessee u/s 147 r.w.s. 143(3) of the Act was without jurisdiction and deserves to be reduced to nullity.

Reliance in this regard is placed on the following judgments:

Commissioner of Income Tax V/s Chetan Gupta 62taxmann.com249 DEL-HC (Pages 15-29 of Jug Set) Shri Rathi Steel Ltd. V/s Assistant Commissioner of Income Tax 104 taxmann.com 400 Del-Trib. (Pages 9-14 of the Jug Set)

Charan Singh V/S Ito Ward- Bhiwadi Of The ITAT, Jaipur Bench Ita No. 906/JP/2018 (Pages 1-8 of the Jug Set)

CIT Vs. Naveen Chander (P&H HC) 323 ITR 49 S Wg. Cdr. Sucha Singh Vs. Ito As Reported in Ita No. 1605/Del/2012

Moreover, the contention of the AO, in Para 6 (Page 3) of his order, that since the Assessee attended the assessment proceedings and filed a return u /s 148 of the Act, the service of notice can be assumed to have been made is wrong and is against the facts of the case. Ld. AO has mistaken in assuming the bonafide act of the assessee to abide by the proceedings of income tax department, after he got to know about such proceedings in his case through service of notices u/s 142(1) of the act, as the waiver of his rights to challenge the jurisdiction assumed by the AO without service of notice u/s 148, which is against the facts and circumstances of the case.

Judgement relied by AO & CIT(A) Distinguished: V.R.A. Cotton Mills (P.) Ltd. reported at [2013] 359 ITR 495 (PH HC) is based on the issue of ‘time limit for issue of notice’ wherein it was held that the date of service of notice is not relevant, incase the notice was issued within time limit and served after the time limit for issue of notice.

However, in the case of the assessee, the notice u/s 148 was never served on the assessee during the assessment proceedings and therefore the aforesaid judgement is not at all applicable to the case of the assessee.

Further the re-opening of the case u/s 148 is bad in law due to the following reasons:

Factually wrong ‘Reasons to believe’

The case of the assessee has been based on reasons to believe that the income has escaped assessment to the tune of Rs. 63.51 lacs being the full transaction value of the property alleged to be purchased to by the assessee. However, during the assessment proceedings itself, the AO has revised the assessment to the share of the assessee invested in such property at Rs. 28.04 lacs, (wrongly taken equal to the sources of investment in such property explained by the assessee instead of Rs. 27.81/- being the share of the assessee in such property purchase).

It is clear from the above that the case of the assessee was reopened on the basis of factually wrong reasons and reassessment based on such faulty reasons to believe must be restored to nullity.

Reliance in this regard is placed on the recent judgement of the Hon’ble ITAT, Amritsar in the case of Gaurav Joshi vs ITO, as reported at 197 TTJ 946 Asr-Trib., placed at Pages 30-35 of the judgement set, wherein the assessment was held to be invalid for factually wrong reasons recorded as the amount alleged m reasons to be deposited hi bank and actual amount deposited were found to be different during the assessment proceedings.

Monika Rani vs ITO in ITA No.582/Chd/2019 dated 28.02.2020

Sagar Enterprises vs. ACIT (2002) 257 ITR 335 (Gujarat High Court)

Harjeet Singh Vs ITO (ITAT Delhi), order dated 12.11.2018, in ITA No. 2013/DEL/2015 KMV Collegiate Sr. Sec. School v. ITO (2017) 163 ITD 653(Asr.) (Trib.):

From the above discussion, it is evident that both the reasons recorded by the AO for reopening the completed assessments of the assessee are based on factual errors, rendering the notice issued u/s 147, finding its basis in the aforesaid reasons, to be an invalid notice, in keeping with the decision of the Hon’ble Supreme Court in ‘Kelvinator of India Ltd.’ (supra), as considered in ‘Dr. Ajit Gupta’ (supra). Consequently, all proceedings pursuant thereto, culminating in the impugned order for the A.Y. 2007-08, are also field to be null and void.

Baba Kartar Singh Dukki Educational Trust v. ITO (2016) 158 ITD 965 (Chd.)(Trib.)

  • Reasons to Suspect and Not Reasons to Believe

The fact that the amount alleged in reasons to believe as having escaped assessment was revised during the assessment proceedings clearly shows that the reasons were actually reasons to suspect and made with the intent of making roving enquiries without any evidence against the assessee in this regard, which is prohibited by law.

Further reliance in this regard is placed on the following judgements, wherein for missing ‘reasons to believe’, the assessments were reduced to nullity, namely:

Amrik singh vs ITO reported at 142 DTR 6 ASR-Trib.)

Placed at Pages 51-64 of Jud. Set

Holy Faith International Pvt. Ltd. vs DCIT in ITA no. 181/Asr/2017 Asr-Trib. Placed at Pages 75-89 of the Jug. Set

Pr. CIT vs Meenakshi Overseas reported at 82 Taxmann.com 300 (Del HC) Placed at Pages 118-129 of the Jud. Set

Mechanical satisfaction of the Pr. CIT for approving Re-opening Notwithstanding the submissions above, your kind attention is brought to the fact that the Ld. Pr. CIT, Karnal has simply stated ‘Yes, I am Satisfied’ while approving the reopening of the assessment in case of the assessee. Thus, the proceedings initiated u/s 147 based on such mechanical satisfaction are also void ab initio. Reliance in this regard is placed on the judgements of:

Hon’ble MP High Court in the case of CIT vs S. Govanka Lime and Chemical Ltd reported at [2015] 56 taxmann.com 390 (Madhya Pradesh)

Hon’ble Apex Court in the case of CIT vs S. Govanka Lime and Chemical Ltd, dismissed the appeal of the department against the aforesaid order of MP HC, vide its order dated 08.07.2015 reported in 12 TMI1334 (2015)/237 Taxman 0378 (SC) (2016)

Hon’ble IT AT Delhi in the case of ITO vs M/s Observer Investment & Finance Pvt. Ltd. In ITA No. 1185 & 1186/Del/2009 & CO No. 118 & 119/Del/2009 dated 24.02.2016;

6.1  The decision of the CIT(A) in holding “ …..the notice is issued within the prescribed time limit for issue of notice u/s 148 of the Act.” was assailed on the grounds that it evaded the issue.

7. The order was assailed on the ground that the approval granted was assailed as a mechanical exercise of power and hence the order deserves to be quashed on the basis of the following submissions :

1. The assessee clearly brought on record the evidences in support of her claim.

However, the AO clearly ignored the submissions of the assessee made in this regard. Infact, on an inspection of the file a copy was taken of the evidences filed by the assessee in support of her claim.

Your attention is brought to the fact that the assessee was maintaining a list of remittances in a hand-written diary and the typed version of which containing the details of the remittances received by the assessee’s husband and her close relatives from her son Sh. Daljinder Singh living abroad, directly or indirectly was duly placed on record, showing evidence of source of fund Rs. 20 lacs approx. received from abroad. Also sample Money gram and Western union receipts were duly placed on record. Copy of sample Western union receipts Placed at Pages 39-40 of the PB and copy of list of remittances placed at Page 46 of the PB. Also, the copy of the relevant extract of hand written diary being furnished separately for your ready reference.

However, the without any giving any benefit of such evidences placed on record and without any finding of fact against the assessee that she had income from any other source during the relevant period the contention of assessee was rejected by the AO and no benefit was given to her for the sources shown by her.

Infact, the sources explained have been added by the AO as the income of the assessee instead of the share of the assessee in the purchase of such property luring the relevant year, clearly showing the carelessness and gross un-justice done to the assessee at the hands of the AO.

Other than the above the assessee and her husband had household savings from the agricultural income of the husband of the assessee and remittances received from their son in the past, sample J forms placed at Pages 31-38 of the PB)

Thus, the fact remains that the sources of the investment in the impugned property for the share of the assessee was duly explained and were simply ignored by the AO and thus the addition made in this regard clearly deserves ” be deleted, even on that basis.

8. On merits, the following arguments were advanced :

Income for the Purchase of Property by the assesse

9. Attention was invited to the following documents and evidences on record:

Copy of the reply filed before the Ld. AO on 12.09.2017 explaining the sources of purchase of the share of the assessee in the impugned property purchased during the relevant period along with the following relevant annexures:

i) Copy of the Purchase Deed of the impugned land purchased by the assessee during the relevant period.of value 63,51,000/- in which the assessee had a share among 4 other buyers.

ii) Copy of the bank statement of the assessee with SBI, Pehowa for the relevant period

iii) Copy of the proof of money sent by the assessee’s son Daljinder Singh from abroad to her Canara Bank account in the years prior to the relevant period

iv) Copy of sample J forms evidencing the agricultural income of the husband of the assessee

v) Copy of sample Western Union receipts evidencing the money sent to the assessee’s husband by her son Sh. Daljinder Singh living abroad, in the years prior to the relevant period.

vi) Copy of the letter filed on 18.12.2017 to the JCIT, Kurukshetra for intervention u/s 144A of the Act in case of the assessee

vii) Copy of the reply of the assessee filed on 26A2.20M as filed before the AO, again explaining the sources of purchase of the share of the assessee in the impugned property purchased during the relevant period along with the following relevant annexures:

i) Copy of the bank passbook of the husband of the assessee Sh. Swaran Singh, with State Bank of Patiala Pehowa Branch updated till the relevant period

ii) Copy of the detailed list of remittances received by the assessee & her family from their relatives abroad

viii) Copy of the reply of the assessee dated 27.12.2018 as filed before the Worthy CIT(A), Karnal in the first stage appellate proceedings.

10. The ld. Sr.DR relied upon the impugned order. The arguments on facts on the legal issue of the maintainability of the addition on merits were not specifically addressed.

11. I have heard the submissions and perused the material on record. It is seen that the assessee has consistently maintained its challenge that notice was not issued as it has not been served. The tax authorities have rejected the challenge holding that non-receipt is not equivalent to non-service. It is seen that though the challenge is recorded the wording in its rejection has been remained ambivalent as no specific finding is found to have been given holding that the notice was issued on a specific date. Nor is there any reference addressing the mode and manner of its issuance nor the fact that it was issued at the correct address. In order to hold that the notice was issued, these above facts need to be recorded and available on record so as to enable an adjudicating authority to conclusively uphold the finding as otherwise sans facts the conclusion is open to the challenge of being arbitrary dehors facts and hence non-maintainable. Thus, though the dismissal of the ground in the manner worded in the face of the challenge does not inspire much confidence in its correctness, however, even otherwise, I find that the assessee has a good case on the legal challenge posed as well as on merits. No doubt mention of the full investment value finds a mention in the “reason to believe”, the fact remains that addition has been made proportionate to the assessee’s share. This fact by itself may not lead generally to the conclusion that the re-opening was mechanical. However, in the facts of the present case, when the Sale Deed is taken into consideration, it is clearly evident that it spells out the fact that only part consideration was moving from the assessee and thus if this bare document itself had been seen before the formation of the belief by the A.O. then while recording the reasons the AO would not have recorded the entire consideration as assessee’s contribution and would have noticed that there were other contributors also. The fact that this document was properly seen at the assessment stage as ultimately instead of Rs. 63.51 lakhs was limited to Rs. 28,03,753/- i.e. the assessee’s share. No doubt the assessee was not a regular tax payer and thus, no return could be consulted by the Assessing Officer while exercising the powers of re-opening. However, the fact remains that it was incumbent on him to at least check the facts recorded in the Sale Deed carefully ascertaining the extent of the assessee’s contribution. Since the facts set out in the Sale Deed cognizance of which was taken by the Assessing Officer himself while making the addition were un-disputably clear as is evident from Paper Book pages 10, 11, 11A and 12 the conclusion that admittedly its proper consideration escaped the notice of not only the A.O. but the approving authority also is clearly evident from record. Thus not finding fault in the manner of the specific words recorded in the order to grant approval, which has been the crux of ld AR’s argument the objection is sustained on the fact that no care or attention evidently was taken to consider the bare preliminary facts itself and the power was exercised mechanically without examining the record. An authority vested with the onerous powers of re-opening u/s 147 and granting of approval is expected to exercise its power consciously, carefully and with full awareness. The public at large cannot be put to the mercies of careless, casual, arbitrary or whimsical exercise of power. The order deserves to be quashed on this count itself. Ordered accordingly.

12. Since arguments have been advanced on merits also I deem it appropriate to address these. On a careful consideration of explanation offered right at the assessment stage partially recorded in the order, I find that even on merits the assessee has sufficiently explained the availability of funds. Specific reference is made to the explanation offered at the first instance before the AO itself:

TOTAL AMOUNT OF PURCHASE-DEED RS. 65.51.000/-.

I purchased agri. land measuring 24 kanals at Village Saraswati Khera along-with other co-sharers Surinder Kaur, Satvinder Kaur, Baljinder Kaur & Ravinder Kaur, residents of Village Nivarsi, tehsil Thanesar for Rs. 63,51,000/- + 190000/- stamp-duty and my share of investments comes out of Rs. 27,81,000/-, the above co-sharers invested the amount of their share themselves, document was registered as per collector-rate. Sir, as per facts of the case, the above land was under the possession of third-parties but we did not pay the amount to the sellers as per the amount written in purchase-deed but paid the amount much lessor, I am enclosing the documents of civil-suit, court-order and the order of concerned Tehsildar for your kind consideration.

2. SOURCE OF INVESTMENT:-

I am house-wife, my husband is retired employee of Haryana roadways, my son & daughter are well settled in abroad, sources of income of family are agri. income, pension and gifts sent by our son & daughter on special occasions, in-fact the above land is purchased by my family & my husband arranged the money (out of his previous & past savings of agri. income, retirement-benefits, gifts received from son & daughter for the purchase of agri. land) and at the time of registering the document at pehowa tehsil “he was advised by a document writer to get it registered in the name of any lady and by doing so you would be benefited of 2% of stamp-duty,

So to avoid 2% of stamp-duty he got registered the document in my name but otherwise the true facts are the above property belongs to my family and everybody contributed. I am enclosing the relevant papers as a proof of investment by each of our family members.

YOUR HONOR IS REQUESTED TO FINALIZE THE ASSESSMENT PROCEEDINGS KEEPING IN VIEW THE TRUE FACTS OF THE CASE AND EVIDENCES GIVEN IN A PAPER-BOOK.

12. I have seen the evidences relied upon at page 13 which ld. AR has clarified, were money transactions from a Middle East country where the assessee’s son was working who ultimately shifted to USA. The money transfer details clearly establish sufficiency of funds. No infirmity in the evidences relied upon and available on record has been pointed out. Satisfied by the availability of funds, I find that even on merits, the assessee deserves relief. Ordered accordingly.

13. In the result, the appeal of the assessee is allowed. Order pronounced on 25.05.2021.

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