Vildirect: IncomeTax-caselaws-1998-VIL-119-ITAT-MUM

1998-VIL-119-ITAT-MUM

Income Tax Appellate Tribunal MUMBAI

IT APPEAL NO. 9683 (BOM.) OF 1995

Date: 30.09.1998

INDIAN MACHINE TOOLS MFRS. â ASSOCIATION

ASSISTANT DIRECTOR OF INCOME-TAX

For the Petitioner : S.E. Dastur and P.J. Pardiwala
For the Respondent : R.K. Rai

BENCH

T.V. RAJAGOPALA RAO, PRESIDENT AND J.K. VERMA, ACCOUNTANT MEMBER

JUDGMENT

Per Shri J.K. Verma, Accountant Member –

The assessee in this case is a company registered under section 25 of the Indian Companies Act, 1956, and hence it was not required to put the words "Limited" after its name. The company was incorporated for the protection of the industries for the manufacture of and the trade and commerce in, machine tools, small tools, cutting tools, foundry, furnace and moulding equipments and machine tools accessories in India and to consider all questions connected with such manufacture, trade and commerce. This is the main object given in the Articles of Association and thereafter supplementary objects and ancillary objects have been given. The incidental or ancillary objects include organising exhibitions in India or abroad on behalf of the Associ-ation or in cooperation with others. The assessee is registered u/s 12A of the Income-tax Act. In this background the assessee filed its return of income at Nil. The Assessing Officer noted that out of its total receipts, receipts to the tune of Rs. 4,76,80,230 pertained to a trade fair/exhibition organised by the assessee called IMTEX-92 at Pragati Maidan, New Delhi, in March 1992. He noted that 86.29% of the total receipts of the assessee were from organising this trade fair. He also noted that the net surplus earned by the assessee was Rs. 1,72,15,212 from IMTEX-92. He observed that these were the profits earned by the assessee from the activity which is business activity and not incidental to the attainment of the objects of the assessee association. After taking into account the explanation given by the assessee before him claiming that this income was not taxable, the Assessing Officer discussed in detail the activities of the assessee in organising this trade fair and after taking into account a good number of decided cases of the Hon’ble Supreme Court and the meaning of the word "incidental" occurring in section 11(4A) and after taking into account the explanations and clarifications filed by the assessee, he held this surplus to be the assessee’s taxable income. His view was that since the assessee has been carrying on these activities in a regular and organised manner almost every alternate year, and the assessee was earning profits from this, it was a business activity. As mentioned above, he also held that it was not incidental to the attainment of the objects of the trust and that no separate books of account were maintained by the assessee and hence the income was liable to tax.

2. The assessee went in appeal. The learned CIT(A) discussed the case law on the subject along with the facts and circumstances of the assessee’s case in great detail. He finally held that the activities of the assessee amounted to carrying on of business but they were incidental to the attainment of the objectives of the assessee. However, since the assessee had not maintained separate books of account, as per the provisions of section 11(4A), the assessee could not be allowed to get the benefit of exemption of its income from tax. He therefore dismissed the appeal filed by the assessee.

3. In the appeal filed before us, the learned counsel for the assessee submitted that the incidence of tax in the case of a charitable trust or institution like the assessee could be considered by taking three criteria into account, namely, (1) whether surplus or profit earned is from business; (2) whether that business was incidental for attainment of the objectives of the assessee and (3) if it was business, whether separate books of account were maintained by the assessee. He argued that in the appeal before us in ground Nos. 2 to 4, the assessee has challenged the findings of the CIT(A) that the assessee was engaged in business activity and in ground Nos. 5 and 6, the assessee has challenged the findings of the CIT(A) that no separate accounts were kept by the assessee. He proceeded urging that if the assessee proves that IMTEX-92 was not business, it would automatically get exemption according to section 2(15) read with section 11(4A) of the Income-tax Act. The second factor mentioned above, namely, whether even if it was business, it was incidental to the attainment of the objectives of the assessee association/institution, has been decided by the learned CIT(A) in assessee’s favour and the revenue has not challenged it in any cross objection and hence this is final. Therefore, according to Shri Dastur, the assessee would succeed if it is accepted that the profits/surplus from IMTEX-92 was not profit from business. If this is not accepted, the assessee would still succeed if it proves that it had maintained separate accounts for that business.

4. Regarding its being business, the learned counsel referred to the Memorandum of Association, a copy of which has been filed before us, and pointed out the ancillary objects, which we have already mentioned above, include holding of trade fairs and exhibitions. He submitted that as mentioned in items 12 and 14 of those objectives, the holding of exhibition and trade fairs was to encourage knowledge pertaining to the various manufacturers and traders, etc., for the protection of whose interests the association had been formed. The learned counsel drew our attention to the decision of the Tribunal in the case of Plastindia Foundation v. ADI (IT Exemption) [IT Appeal No. 5523 (Bom.) of 1994 dated 31-5-1993] for the assessment year 1990-91, a copy of which has been filed before us. He explained that although that decision was in respect of the assessment year 1990-91, but the modification of sub-section (4A) of section 11 with effect from 1-4-92 would not have any adverse effect on the assessee’s case. He submitted that the amended sub-section is more liberal than the erstwhile sub-section (4A). According to him, the word "incidental" has a wider scope because an activity could be incidental without fulfilling the requirements of the erstwhile sub-section (4A). Therefore, the decision in Plastindia Foundation’s case (supra) fully covers the assessee’s case. He stated that according to the Tribunal in that case, holding of exhibitions was not business if it was for furtherance of the objects of the assessee. He also referred to the decision of Thanthi Trust v. CBDT [1995] 213 ITR 639 (Mad.) in which on page 642 it was held that when a trust was furthering its objectives, it could not be considered to be business. On this basis, the learned counsel claimed that if this proposition was accepted in the assessee’s case, the assessee’s income would become exempt and ground numbers 5 and 6 would become redundant.

5. Regarding its alternative grounds, namely, ground Nos. 5 and 6, which are based on the assumption that the activities of the assessee in organising IMTEX-92 are considered as business, the only other question which would survive for our decision would be whether the assessee had maintained separate books of account, because as mentioned earlier, the learned CIT(A) has already accepted the assessee’s contentions that those activities were incidental to the attainment of the objectives of the assessee-association. In this regard, the learned counsel argued that maintenance of separate books of account was only a procedural require- ment. He submitted that the purpose of this requirement was that the assessee should be able to identify the profits. According to Shri Dastur, it would mean that "entries" cannot be made in same account books. He submitted that in this case separate ledger accounts had been maintained for exhibition and thus these books distinctly set out the profits of exhibition. He referred to page 3 of the assessment order where the learned Assessing Officer had given the exact figures of both the receipts and expenses upto the last Rupee. Similarly, he pointed out, on page 11 of the assessment order, the Assessing Officer had worked out the exact surplus to the tune of Rs. 1,72,15,212. He stated that for exhibition, there is a separate ledger account maintained for each and every item. He filed copies of these ledger accounts before us. He referred to the balance sheet of the assessee, copy of which has been filed before us showing that Schedule-10 showed the expenses and Schedule-6 showed the receipts and income. He stated that for each of these items given in the Schedule, there is a separate account in the assessee’s books, i.e. regarding rent, sale of passes, telephone expenses, etc. In this way, according to the learned counsel, this would show that in the assessee’s accounts there are separate ledger accounts for income and expenses of IMTEX-92. He argued that we have to consider the intendment behind the words in the sub-section, which would mean "separate accounts" and not "separate books of account". He claimed that the Assessing Officer had found no difficulty in determining the profit, which had been determined upto the last Rupee. He argued that the machinery provision should be interpreted to further the main purpose and not to defeat it. In this context he referred to the decision in the case of CIT v. Sitaram Bhagwandas [1976] 102 ITR 560 (Pat.). He pointed out that in that case, on the question whether the Form No. 12 for registration of the firm had to be filed along with the return, it was held that the provisions were only directory and not mandatory. Similarly, in the case of Mrs. Sudha Sharma v. ITO [1993] 44 ITD 351 (Delhi), it was held that for the purposes of section 80HHC, the auditors’ certificate, which, according to the section, is required to be filed along with the return, could be filed at any time before the completion of the assessment. He submitted that to similar effect is the decision of Hon’ble Bombay High Court in the case of CIT v. Shivanand Electronics [1994] 209 ITR 63/ 75 Taxman 93. Similarly, in the case of CIT v. London Hotel [1968] 68 ITR 62 (Bom.), in respect of the words "actually written off in the books of account" for claiming balancing allowance on WDV, it was held that it was not always necessary to write off in the books of account. Therefore, according to Shri Dastur, "separate books of account" in section 11(4A) would not mean that the assessee should buy separate books and make separate entries in those books. He also referred to the decision in the case of CIT v. Kartar Singh [1970] 77 ITR 338 (Punj. & Har.) where it was held that even if a separate memorandum book was kept, it could be treated as a book of account. Hence, if in the assessee’s case, the assessee could sit down and copy these entries on a separate memorandum book, it should have meant compliance of the requirement of the sub-section. He urged that for failure to do this only, there should be no denial of benefit of exemption from tax to the assessee.

6. The learned DR argued that with effect from the assessment year 1992-93, there was a substantial change in the provisions of section 11(4A). Accordingly, it had to be decided in this appeal whether organising the trade fair and the exhibition was business or not and whether the assessee’s income from that was taxable or exempt. He started with the alternative ground taken by the learned counsel for the assessee and argued on the assumption that if it was business, whether the assessee had complied with the requirements of section 11(4A) by maintaining separate books of account. He emphasised that according to the provisions of that sub-section, it was essential that "separate books of account are maintained by such trust or institution in respect of such business". According to the learned DR, it was essential that the assessee must have maintained separate books of account for the IMTEX-92 and not merely that its profits and expenditure could be found out from the common books of account maintained by it. Regarding the arguments of Shri Dastur, he referred to the observations in an English case which have been cited with approval on page 54 of 121 ITR by Their Lordships of the Supreme Court while concluding their decision in the case of Addl. CIT v. Surat Art Silk Cloth Mfrs. Association [1980] 121 ITR 1/[1979] 2 Taxman 501 . It reads :-

". . . in a taxing Act one has to look merely at what is clearly said. There is no room for intendment. There is no equity about a tax. There is no presumption as to a tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at the language used."

And again on the same page, while again quoting with approval from another English decision of House of Lords which dealt with the "Harsh consequences of a taxing provision" it was quoted as under :-

". . . If the meaning of the provision is reasonably clear, the courts have no jurisdiction to mitigate such harshness."

Thereafter, their Lordships have themselves observed :-

"Judicial attitudes cannot be formed in isolation from legislative processes, particularly in connection with tax avoidance provisions."

Referring to the reference of Shri Dastur to the commentary of Chaturvedi and Pithisaria (Volume 1) (Fourth Edition) (page 457) where it is written that the provisions had to be liberally construed, he submitted that it also qualifies it by saying that such liberal construction should not do violence to the language of the Statute. Regarding the case law cited by the learned counsel for the assessee with reference to section 80HHC, the learned DR submitted that the ratio of that decision could not be relied upon in support of the assessee because the language of section 11(4A) was very clear; it was only when the language of the statute was not clear, there was room for interpretation. Referring to the decision in the case of London Hotel (supra) relied upon by the learned counsel for the assessee, he pointed out that on page 78, their Lordships had made it clear that in the circumstances of the case, the assets could not be found in the books of the assessee firm because they were always treated as the personal assets of the partners and hence it was for not fault of the assessee that he could not actually write off the amount in his books. Further, they observed that, on the contrary, the default, if any, arose simply because long after the accounts of the relevant years were closed, the Income-tax Officer chose to take the view that the assets in respect of which an allowance was claimed were not the personal property of the partners as the partners always treated it, but were the business assets of the firm of which the three co-owners were the partners. He referred to rule 6F(2) of the Income-tax Rules and pointed out that the books of account mean a cash book, a journal if the accounts are maintained according to mercantile system, a ledger, carbon copies of bills etc., original bills etc. In this background, the separate ledger account argued by Shri Dastur could not be taken as a separate ledger. He further referred to the meaning of the word "separate" in the Chambers Dictionary, according to which, it meant "physically disconnected, forming a unit that is or may be regarded as a part or by itself". Even as a verb, it means to divide, to part, and in this background, when the accounts of IMTEX-92 were kept in the same books, it could not be said that the assessee had kept separate accounts, much less separate books of account. Dealing with the case of Kartar Singh (supra ) cited by the learned counsel for the assessee, he explained that what was considered there was books of an assessee and whether any memorandum was part of the books of the assessee and it was held that it was part of the books, but in the instant case, the question to be considered was whether the assessee has maintained separate books of account for such business.

7. Coming to the first ground, as to whether IMTEX-92 constituted business, he referred to pages 3 to 9 of the assessment order and submitted that the order showed that the assessee had been holding the exhibitions almost every alternate year. In particular, he referred to page 4 of the assessment order where the Assessing Officer had specifically mentioned this fact and this fact had not been disputed by the assessee at any stage. He drew our attention to the details regarding the tariff rates, the schedule of payments and the conclusion of the Assessing Officer on page 8 of his order. The learned DR referred to the decision in the case of All India Spinners’ Association v. CIT [1944] 12 ITR 482 (PC) where, on page 483 it was noted that general public utility could exclude the motive of private gain - what is private gain - if commercial profit taken, it is private gain. He submitted that in the instant case before us, the assessee had computed its profits on a commercial basis and hence even if the assessee-association is for general public utility, it is earning profits as private gain, on commercial basis, and hence it has to be considered as business. He again referred to the decision of Surat Art Silk Cloth Mfrs. Association’s case (supra) where their Lordships have referred with approval to the observations of Beg, J. in the case of Sole Trustee, Loka Shikshana Trust v. CIT [1975] 101 ITR 234 (SC) in which Justice Beg had observed :

"the use of the words ‘for profit’, however, shows that the involvement of profit making should be of such a degree or to such an extent as to enable us to infer it to be the real object. As a rule, if the terms of the trust permits its operation ‘for profit’, they become, prima facie, evidence of a purpose falling outside charity."

Referring to the decision in the case of CIT v. Sivakasi Hindu Nadars Uravinmurai [1996] 217 ITR 118/ 86 Taxman 290 (Mad.) relied upon by the learned counsel for the assessee to the effect that if the objects are given in the trust deed as general public utility, it should be accepted to be charitable purpose, the learned DR submitted that this was not a correct interpretation of the judgment. According to him, on page 129 of the decision, the Hon’ble Court had held that the Tribunal had gone wrong in granting exemption only on the basis that the object clauses of the Memorandum of Association made obligatory upon it to carry on the general public utility activities like educational institution, libraries etc., and in inferring that, there is nothing in these clauses to show that the assessee is obliged to carry on general public utility activity like educational institutions, library etc., on a purely commercial basis and not on the marginal no profit no loss basis as laid down in Indian Chamber of Commerce v. CIT [1975] 101 ITR 796 (SC). The Hon’ble Court observed: "This error is obvious." He emphasised that for this purpose also, it was necessary that the assessee had maintained separate books of account for such business. He submitted that the learned CIT(A) had held that holding IMTEX-92 amounted to business. He also referred to section 2(13) of the Income-tax Act defining "Business" and pointed out that it includes trade, commerce or manufacture or any adventure or concern in the nature of trade, commerce or manufacture. According to him, as per this definition and a large number of decided cases, an assessee carried on business if it carried on an organised activity on a regular basis. He submitted that in the instant case, the assessee’s balance sheet showed that whereas the assessee’s receipt from membership was only Rs. 4.61 lakhs and from miscellaneous receipts Rs. 71.15 lakhs, from exhibition it was Rs. 4.76 crores. This shows that the major activity of the assessee was organising the exhibitions almost every alternate year with a view to earning profits. Regarding the case of Thanthi Trust (supra), it is stated that the issue in this case was in connection with the provisions of section 13(1)(bb) which is no longer on the statute book and hence according to him it was obvious that the assessee was carrying on business activity. Regarding the case of Plastindia Foundation ( supra), he submitted that that pertains to the assessment year 1990-91 when the law was different and the Tribunal in that case was dealing with section 11(4A) prior to its amendment with effect from 1-4-92. Moreover, according to him, several cases now cited before us were not cited before the Tribunal in the case of Plastindia Foundation (supra). He referred to the decision in the case of Prabodhan Prakashan v. Asstt. Director of IT [1994] 50 ITD 135 (Bom.) and submitted that applying the criteria of that case it would be obvious that the assessee before us had been doing business and was not keeping separate books of account.

8. In his rejoinder, Shri Dastur submitted that the assessee had been holding exhibitions in the past also but the view that it was business was never taken by the revenue. He submitted that like Plastindia Founda- tion’s case (supra) in the assessee’s case also the purpose is charitable. He referred to the photographs in the brochure, copy of which has been filed before us, and pointed out that the Hon’ble President of India had visited the exhibition and had conveyed his blessings to it. He submitted that this would show that the purpose of this exhibition was to popularise and help the business and industry for which the Association has been formed. Regarding the DR’s argument that taxation law should be strictly inter-preted, he pointed out that as per p. 457 (Volume-1) of Chaturvedi and Pithisaria (supra), when it comes to exemption, the language is to be liberally constructed and benefit should be fully given and should not be whittled down. Further, even if it has to be strictly interpreted, the assessee had established that its objects are charitable and hence it is entitled to the treatment due to a charitable institution. It was for the Department to show that the assessee was carrying on business and had not maintained separate books of account. Regarding the dictionary meaning of the word "separate", the learned counsel submitted that it was a recognised princi- ple of interpretation of statutes that a statute cannot be interpreted with dictionary in one hand and the statute in another. According to him, even if the meaning "isolate" is taken, he submitted that in the assessee’s case, the profits from the exhibition had been isolated and this would mean separate books of account had been maintained. Regarding the case of Prabodhan Prakashan (supra) referred to by the learned DR, he pointed out that in that case the donations were made for the corpus. Moreover, the assessee itself had accepted that it was carrying on business and hence had claimed set-off of earlier losses which the Tribunal had allowed. He submitted that various other case law cited by the learned DR was to determine whether the purpose of those institutions was charitable or not, in the case of the assessee it could not be disputed that its purpose was charitable.

9. We have carefully considered the rival submissions, the material on record and the detailed arguments given by the Assessing Officer and the learned CIT(A) in their respective orders. In our opinion, no useful purpose would be served by reproducing the arguments on the issue as to whether the purpose of the assessee is charitable or not. It cannot be denied that the purpose for which the assessee-association was formed was for the general benefit of various types of trade and industry and in view of the case law cited by the learned counsel, including several decisions of the Hon’ble Supreme Court on this issue, we accept that the purpose of the assessee-association is charitable. It is further proved by the fact that it is registered as a company under section 25 of the Companies Act and is also registered under section 12A of the Income-tax Act by the Income-tax Department itself. However, the questions which remain to be decided are, whether the holding of exhibitions by the assessee in this case amounted to business and, if so, whether separate books of account had been kept for that. From the detailed arguments advanced by the learned DR, it is obvious that the assessee has been organising the exhibitions and fairs almost regularly after every alternate year. We have also noticed from the balance sheet of the assessee that as against very nominal amounts received by the assessee in connection with its normal association activities, it had collected more than Rs. 4.76 crores by way of receipts for organising the trade fair/exhibition. The details on record, and as pointed out by the Assessing Officer, show that it was not as if some nominal fees were being charged from participants, including the members of the Association. The details further show that it was a very well-organised activity and out of which, according to the assessee itself, the net savings were to the tune of about Rs. 1.72 crores. The balance sheet further indicates that the assessee’s funds are being utilised in increasing investments rather than being utilised in expenditure for the benefit of the trade and industry for which the Association is made. Moreover, from the decision in the case of Plastindia Foundation (supra), heavily relied upon by the learned counsel for the assessee, it cannot be gathered that it was a regular activity of that Association. In fact, the Tribunal has observed in that order that when that assessee decided to hold trade fair for the benefit of the plastic industry and also to publicise and popularise the use of plastic, for which it invited foreign participants, it could not be ascertained whether finally it would result in profit/surplus or loss. On the other hand, in the case of the assessee before us, as mentioned earlier, it is not for the first time that the assessee has organised such an exhibition. The surplus which it has got from this exhibition itself, i.e., IMTEX -92, shows that it had been organised, with the past experience, to collect substantial amount of money. This would show that these were not the activities run on ‘no profit no loss basis’ or only on the basis of earning marginal profits, which was considered by the Hon’ble Supreme Court in the case of Indian Chamber of Commerce (supra). For these reasons and for the detailed reasons given by the learned Assessing Officer and the learned CIT(A) in their respective orders, we are unable to agree with the arguments of the learned counsel for the assessee that the surplus/profits and gains from the IMTEX-92 were not profits of business. In our opinion, since it was a well-organised and regular activity for earning surplus almost every alternate year, the profits and gains arising from this have to be held as being profits and gains of business.

10. As rightly pointed out by the learned counsel for the assessee, the learned CIT(A) has held that this business was incidental to the attainment of the objects of the trust and this finding has not been challenged by the revenue. This leads us to decide the issue, and the main issue, as to whether the assessee had maintained separate books of account for such a business. Although there is a lot of force in the illustrations and examples and analogies given by the learned counsel for the assessee to convince us that in the first instance, since the surplus and expenditure from IMTEX-92 can be and has been isolated, it should be accepted that the assessee had maintained separate books of account for such a business, yet we find that in view of the legal position and the principles of interpretation of statutes we are unable to accept his arguments. It is a basic principle of the interpretation of any statute that if the meaning of any provision is clear, that clear interpretation should be accepted. It is only when there is some ambiguity in the meaning of any words or provisions that the interpretations and meanings should be derived from such provisions. Another principle of interpretation is that no word used in a statute should be taken to be otiose or redundant unless its literal interpretation would lead to absurdity. Of course, as pointed out by the learned DR, in a taxing statute there is no scope for intendment. Applying these three criteria, we find that, in the first instance there is no ambiguity in the words "and separate books of account are maintained by such trust or institution in respect of such business". What do the books mean, has been clarified in rule 6F, as pointed out by the learned DR. It means that the books of account include cash book, journal, ledger, carbon copies of bills. Further, in Explanation (h ) to that Rule, the word "cash book" has been mentioned as a record of all cash receipts and payments kept and maintained from day to day and giving the cash balance in hand at the end of each day or at the end of a specified period not exceeding a month. In this view of the matter, neither in terms of common parlance nor as can be understood from rule 6F of the Income-tax Rules, it can be accepted that merely because if with certain effort, the total receipts and expendi-ture of a particular business can be found out from the common books of account of the entire institution, it should be accepted that the assessee has complied with the requirements of section 11(4A) of the Income-tax Act. In other words, we find ourselves unable to accept that in the present situation it can be said that the assessee has "maintained separate books of account in respect of such business". In our opinion, if the interpretation of these provisions, as argued by Shri Dastur, was what the Legislature intended them to mean, it could have simply written that the assessee has accounted for such business in its books of account. It was not necessary to use the words "separate books of account" and only the word "accounts" could have been sufficient and then "in respect of such business" should not have been necessary and merely "should have maintained accounts" should have sufficed. Secondly, we find no ambiguity in the expression "and separate books of account are maintained by such trust or institution in respect of such business". In such a situation it becomes unnecessary to try to give a liberal interpretation or an interpretation which is beneficial to the assessee, etc. Since the words and expressions are very clear, they have to be interpreted as such and we cannot go behind the clear words of the statute to find out whether the ordinary or the popular meaning of the words of the statute is reasonable or not, or their ordinary meaning would bring out the intention of the Legislature or not. It is a well-recognised principle upheld by the Apex Court in several cases that if an assessee wants to avail of any beneficial provisions of the Act, it must strictly comply with it. In our opinion, the analogy given by Shri Dastur with respect to the provisions of section 80HHC or 184(7) etc., would not apply because in those cases some ambiguity did arise and that is why even in the case of Shivanand Electronics (supra) referred to by the learned counsel for the assessee, the Hon’ble Bombay High Court had held that while the Assessing Officer had the option to accept the audit report before the completion of the assessment, the assessee could not claim it as a matter of right and that is why, in fact, in that case the Hon’ble Bombay High Court had answered the question against the assessee and in favour of the revenue. Thirdly, we cannot interpret that any word in section 11(4A) is redundant and would lead to absurdity if literally interpreted. In our view, the intention of the Legislature is very clear and it is to the effect that if a charitable society or institution wants to get the benefit of exemption of its income from business, the business should be firstly, incidental to the attainment of objectives of the trust or institution and, secondly, it must maintain separate books of account for such business. It cannot mean that if this interpretation is given, it would lead to any absurdity.

11. Taking all these factors into account, we uphold the order of the learned CIT(A) and dismiss the appeal filed by the assessee.

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