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I. T. As. Nos. 1404 to 1407/KB of 1984-85, decided on 15th February, 1987.
---S. 166--Income-tax Act (XI of 1922), S. 33(1)--Appeal against order of Inspecting Assistant Commissioner--Only condition prescribed by S.33(1) of the Act of 1922 was the period of limitation of 60 days--Provisions of 5.166, Income-tax Ordinance1979, however, deals with those cases where provisions of S.33(1) of the Act of 1922 have been kept alive for certain purposes.
---Ss. 166(d)(b)(2), 2(7) & 134--Application of S. 166(d) & (b)--Word assessment includes re-assessment and additional assessment- Assessments which are contemplated by S. 166(d) may be either the original assessments or revised or additional assessments made pursuant to an appellate or revisional order--Provision of S. 166(d), however, does not deal with the point of tune at which such return for that assessment year was filed--Where returns were filed much after promulgation of repealed Act of 1922. Provisions of S. 134 of the Ordinance would be applicable to appeals in view of S. 166(2) of the Ordinance.
Section 166(d) of tile Income-tax Ordinance, 1979 deals with those assessments, which are regarding any year ending on or before 30th day of June, 1979, but it makes the provisions of repealed Act applicable which are relating to the computation of total income and the tax payable. In other words it means that at the time of computing total income and the tax payable thereon an Income--tax Officer is required to keep into consideration the rate of tax and those deductions etc., which he was required to make from the income declared which were permissible under, tile repealed Act. Moreover, it deals with those cases ire which an assessment is to be made for any year ending on or before the 30th day of June, 1979. On reading the definition of assessment as contained ire section 2(7) of the Ordinance, it appears that the word assessment includes re-assessment and additional assessment. As such, any type of assessment which are contemplated by clause (d) may be either the original assessment or revised or additional assessment made pursuant to an appellate or revisional order. However, this clause does not deal with the point of time at which such return for that assessment year was filed. Clause (b), on the other hand, squarely deals with this issue. It makes the repealed Act applicable to those returns, which are filed after tile commencement of this Ordinance but, it is important to note, if they are filed in pursuance of any notice issued udder section 34 of the repealed Act and not to those returns which are filets after the commencement of the Ordinance voluntarily. In this case all the returns were filed, much after the promulgation of the Income-tax Ordinance. Argument that in view of clause (b) of subsection (2) of section 166, the provisions of the Ordinance apply to all the appeal., carries much weight. The provisions of section 134 of the Ordinance, therefore, are applicable in the case of the Ordinance regarding all the assessment years.
---S. 134(1)--Appeal to the Tribunal by assessee--Conditions to be satisfied detailed.
If an assessee wants to file an appeal to the Tribunal, he must fulfil the following conditions:-
(i) The order appealed against must be by an Appellate Assistant Commissioner under section 111 or 132 or subsection (2) of sections 148, or under section 156.
(ii) or it should be an order recorded by an Inspecting Assistant Commissioner under section 66-A, and
(iii) Whether it is an order recorded by Appellate Assistant Commissioner or Inspecting Assistant Commissioner under sections mentioned above, it must.--
(a) enhance the assessment;
(b) reduce a refund, or
(c) otherwise increase the liability of the assessee.
---S. 134(b)--Appeal to Tribunal by assessee--Where the Inspecting Assistant Commissioner had concealed all the assessment fur the reasons that interest income declared by the assessee was the income of his wife and should be taxed accordingly, the Inspecting Assistant Commissioner had in effect reduced the tax liability of the assessee, as such appeals by assessee, against order of Inspecting Assistant Commissioner were not maintainable in law.
---S. 83--Income from revocable transfer of assets--Word "transfer"- Meaning- -Contention that fixed deposit receipts purchased by husband assessee out of his own funds and wife was merely a Benami-holder thereof--No evidence on record available to show to support contention that husband assessee bought said F.D.Rs. out of his own funds but F. D. Rs. stand in the name of his wife; and as such, income accruing from F. D. Rs. was chargeable to tax as income of assessee husband himself--Income-tax Tribunal repelled contention--Reasons -sated.
It was contended that all the F.O.Rs. were purchased by the appellant out of his own funds and his wife was merely a Benami-holder thereof. There is no evidence available on record to support this: submission. It is true that purchase of an asset directly in name of spouse or child may be deemed as a transfer of asset. It is also true that the word transfer;' as used in subsection (4) and as defined by clause (b) of subsection (5) of section 83 of the Ordinance does not carry the meaning of transfer as contemplated by Transfer of Property Act and purchasing an asset in the name of the wife of the appellant could be deemed to be an "arrangement" which is included within the definition of word transfer' as used in clause (b) of subsection (5) taut, unfortunately, there is no evidence on record to support the contention that the F. D. Rs. were purchased by the appellant out of his own funds but they stood in the name of his wife and, as such, the income accruing from them is chargeable to tax as the income of the appellant himself--Held, the appellant in fact, wanted a declaration from the Tribunal that the appellant was the real owner of the F.D. Rs. which Tribunal cannot, under the facts and circumstances of the appeals, grant to him. If the appellant has any dispute regarding his right, title or interest to the F.D.R. he could be well-advised to go to civil Court to seek a declaration to that effect. As far as the Tribunal was concerned it has no jurisdiction to grant such relief to appellant.
---S. 1.34 (1)--Appeal to Income-tax Tribunal--Provision of S. 134(1) of Ordinance, 1979 desired to be amended on pattern of S. 253(1) of the Indian Income-tax Act, 1961.
The learned counsel for the appellant expressed his astonishment on the wisdom of the Department regarding the taxability of the interest income. He has submitted that the interest income in the hands of the wife has been ordered to be deleted in appeal on one hand, while on the other the learned Inspecting Assistant Commissioner has cancelled all the assessments, thus thereby again excluding the interest income to be taxed in his hands. Indeed the circumstances of these appeals are peculiar but as the law stands I fell very much constrained to uphold the preliminary objection of Departmental Representative. However, before parting with these appeals let me point out that the provisions of section 134(1) of the Ordinance requires to be amended on the pattern of subsection (1) of section 253 of the Indian Income-tax Act, 1961, which is as under:-
- (1) Any assessee aggrieved by any of the following orders may appeal to the Appellate Tribunal against such order--
(a) an order passed by an Appellate Assistant Commissioner or, as the case may be, the Commissioner( Appeals) under subsection (2) of section 131, section 154, section 250, or section 271, section 271-A or section 272-A ; or
(b) an order passed by an Inspecting. Assistant Commissioner under section 154; or
(c) an order passed by a Commissioner under section 263 or under section 272-A or under section 285-A or an order passed by him under section 154 amending his order under section 263."
From perusal of the above-quoted subsections of the Indian Act, it appears that the right of appeal has been given to an assessee who feels aggrieved by any of the orders passed by either the Appellate Assistant Commissioner or Inspecting Assistant Commissioner; or Commissioner under sections mentioned in clauses (a), (b) and (c), as reproduced above. In our repealed Income-tax Act we had also worded its section 33 in quite wide terms. Had I been exercising my jurisdiction under section 33, or under section 253(1) of the Indian Act would have turned down the preliminary objection of the Departmental Representative and, after holding the order of the Inspecting Assistant Commissioner recorded in contravention of section 83(4) of the Ordinance, would have set aside his order and sent the matter back to Income-tax Officer to make necessary investigation regarding the appellant's allegations about the F. D. Rs. and then to frame assessment de novo."
Sirajul Haq Memon for Appellant.
Muhammad Farid D.R. for Respondent.
Date of hearing: 15th February, 1987.
Mr. Muhammad Farid, the learned Departmental Representative, has raised a preliminary objection, regarding maintainability of these four appeals. Before I advert to his submissions, let me first recapitulate here the facts which in themselves are quite interesting. It appears that on 30th January, 1983, the Income-tax Officer of Circle V South Lone, Karachi, received information that the wife of the appellant (the latter admitted is an employee of P. I. A. and an assessee of Circle of P. I.A himself) had in her name the following F.D.Rs.:--
(1) F.D.R. No. 045508, dated 14th January, 1978 for Rs.1,25,000 on which interest amounting to Rs.44,062.50 was paid on let February, 1981.
(2) F.D.R No.045577, dated let February, 1981, for Rs.1,69,062.50 on which interest amounting to Rs.12,037.50 was paid on 12th November, 1981.
(3) F. D. R. No.045578, dated 4th February, 1981, for Rs.1,29,625 on which interest amounting to Rs.9,335 was paid on 12th November, 1981.
Since she has neither declared these F. D. its in her wealth statement nor offered the interest earned from them for tax, the Income-tax Officer, therefore, issued notice under section 65 of the Income-tax Ordinance (hereinafter referred to as "the Ordinance") for assessment years 1978-79, 1979-80, 1980-81 and 1981-82, which was served on her on 24th March, 1983. It further appears that the assessment of the wife of the appellant for assessment year 1982-83 had already been re-opened vide notice, dated 28th December, 1982, on some other ground. While these proceedings were pending the appellant, whose assessment for assessment year 1977-78 was already completed on 28th January, 1978, filed a revised return on 19th May, 1983 for the same year offering the interest earned from F. D. Rs. far tax. He also filed his return of income for assessment years 1978-79, 1981-82 and 1982-83 on 11th May, 1983. In these returns he also declared his interest income derived from the F. D. Rs. which allegedly he had purchased in his wife's name. It further appears that for assessment year 1977-78 the appellant was originally assessed for his salary of Rs.760. However, in his revised return which he filed on 19th May, 1983, he added Rs.4,250 and Rs.9,500 to the amount of his salary amounting to Rs.44,760 alleging that both the amounts of Rs.4,250 and Rs.9,500 were his income from interest on F. D. Ks. which stood in his name and in his wife's name respectively. The Income-tax Officer after receiving this revised return served a notice under section 65 of the Ordinance on the assessee on 19th May, 1983 and after examining the allegation of the appellant alongwith the taxability of the interest income in the hands of the appellant arising out of the F.D.Rs. purchased by him in the name of his wife framed the assessment accordingly. Let me mention at this juncture that in this assessment order only two F.D.Rs. have been mentioned. The first is said to be worth Rs.1,25,000 issued by National Bank of Pakistan, Hilton Branch, Karachi, in the name of the wife of the appellant. It further appears that on 31st December, 1982, it was encashed and it yielded Rs.1, 85, l&4. It also appears that another F. D. R. of Rs.1,00,000 was also from the same Branch of the Bank and it was encashed on 2nd November, 1982 for Rs.1,38,960. However, it is not clear from the revised assessment order as to in whose name this F.D.R. stood. I have gone through all the assessment orders of rest of the years as well, but none of them speak of three F.D.Rs. which were mentioned by the Income-tax Officer in his notice, dated 30th January, 1983. From perusal of the other assessment orders it appears that for assessment year 1978-79 the appellant offered his salary of Rs.62,493 alongwith interest of Rs.16,870 for tax and the assessment was completed under section 23(1) of the repealed Income-tax Act. The assessment for assessment year 1981-82 was completed under section 62 of the Ordinance and the tax was levied on total income of Rs.79,250 which included Rs.792 earned as interest. In assessment year 1982-83 the return was filed under section 59(1) of the Ordinance, and the amount of salary and interest offered were top the tune of Rs.51,066 and Rs. 21, 835 respectively, and the Income-tax Officer framed the assessment accordingly.
2. It further appears that the learned Inspecting Assistant Commissioner of Range-2, Central Range 'D' came across these assessment files of the appellant regarding assessment years 1977-78, 1978-79, 1981-82 and 1982-83. After going through them he thought that all the assessment orders were erroneous in so far as they were prejudicial to the interest of revenue. He, therefore, on 30th September, 1984 issued notice under section 66-A of the Ordinance calling upon the appellant to show cause as to why these assessment orders of the relevant assessment years be not cancelled. After considering the explanation offered by the appellant vide his Advocate's reply, dated 1st October, 1984, found it unsatisfactory for following three reasons:--
"(1) You had not declared this interest income in your original return of income for 1977-78 which had been finalized on 28th January, 1978.
(2) Your wife is an existing assessee.
(3) You revised/filed your returns for these years declaring your wife's interest income to be your's after action under section 65 had been initiated against your wife by I.T.0, Circle V, South, Karachi. "
He, therefore, recorded the following order:--
"Now, therefore, in pursuance of powers exercisable by me under section 66-A, I hold that the above assessment orders are erroneous in so far as they are prejudicial to the interest of revenue. Hence, the said assessment orders are hereby cancelled.
The Income-tax Officer, P.I.A Employee Circle-I will re-frame those assessment orders taking into consideration the income of Mr. S. G. Mujtaba only. The income derived by Mrs. S. G. Mujtaba will be assessed by Income-tax Officer, Circle V South Zone, who holds jurisdiction over her case.
This consolidated order was recorded by him on 19th November, 1984, and the appellant has filed these four appeals to impugne it.
3. Mr. Sirajul Haq Memon, Advocate, appeared for the appellant and Mr. Muhammad Farid, the learned Departmental Representative, represented the Department. However, before reverting to submission of learned Departmental Representative as well as learned counsel for the appellant let me point out here that according to Mr. Sirajul Haq Memon, the assessments of the wife of the appellant regarding assessment years 1978-79, 1979-80, 1980-81 and 1981-82, which were re-opened under section 65 of the Ordinance, were ultimately framed and she was charged tax on the interest income derived from F.D.Rs. but this income has been deleted in appeal. Therefore, presently, according to Mr. Sirajul Haq Memon, the position is that the interest income derived from the F.R.Ds. has neither been taxed in the hands of the appellant because of the appellant order and nor in the hands of his wife in view of the appellate order.
4. Now let me turn to the preliminary objection of Mr. Muhammad Farid, the learned Departmental Representative. Mr. Muhammad Farid started his submission with the premises that the right of appeal being a statutory right cannot be assumed if it was not given by a statute. Then, referring to section 134(1) of the Income-tax Ordinance the learned Departmental Representative argued that an appeal to the Tribunal would be competent only against the order of an Inspecting Assistant Commissioner under section 66-A, if the effect of such order was to enhance the assessment or reduce a refund or otherwise increase the liability of the assessee. The learned Departmental Representative therefore, concluded that since under the facts and circumstances of these appeals neither of the three conditions, mentioned above, had been fulfilled, the appeal was not maintainable. Section 134 may be reproduced with advantage at this stage:--
"
--(1) An assessee objecting to an order passed by an Appellate Commissioner under section 111 or 132, or subsection (2) of section 148, or an order made by the Appellate Assistant Commissioner under section 156, or an order made by an Inspecting Assistant Commissioner under section 66-A having the effect of enhancing the assessment or reducing a refund or otherwise increasing the liability of the assessee may appeal to the Appellate Tribunal against such order.
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Facing this submission of Mr. Muhammad Farid, the learned counsel for the appellant Mr. Sirajul Haq fell upon section 33 of the repealed Income-tax Act, and argued that since the assessment years 1977-78 and 1978-79 were also involved it applied under the facts and circumstances of these appeals, hence the appeals were maintainable in law. Section 33 of the repealed Income-tax Act reads as under:--
-- (1) Any assessee objecting to an order passed by--
(a) an Appellate Assistant Commissioner under section 28, section 30 or section 31,
(b) an Inspecting Assistant Commissioner under section 34-A, or
(c) an Inspecting Assistant Commissioner exercising the powers conferred on an Income-tax Officer under subsection (5) of section 5,
may appeal to the Appellate Tribunal within sixty days of the date on which such order is communicated to him:
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5. I have heard both the learned counsel for the appellant as well as learned Departmental Representative at length and have also perused the relevant sections of both Ordinance as well as the repealed Income-tax Act. It is true that under section 33 of the repealed Act, any assessee who wanted to file an appeal against an order of the Inspecting Assistant Commissioner, had a right to file an appeal provided that he had any objection against such order. The only condition prescribed by aforesaid subsection (1) of section 33 was that of the period of limitation of 60 days. But, I am afraid, this provision does not come to the rescue of Mr. Sirajul Haq. Section 166 of the Ordinance deals with those cases where the provisions of repealed Income-tax Act have bean kept alive for certain purposes. It is true that the learned counsel for the appellant has submitted that the repealed Act remains applicable in the case of the appellant in view of the provision of paragraph (d) of subsection (2) of section 166 of the Ordinance. However, Mr. Muhammad Farid, on the other hand, has vehemently argued that the case of the appellant was covered by clause (b) of subsection (l) of section 166 of the Ordinance. I am reproducing both clauses hereinbelow:--
- (1) The Income-tax Act, 1912 (XI of 1922) is hereby repealed.
(2) Notwithstanding the repeal of the Income-tax Act, 1922 (XI of 1922) and without prejudice to the provisions of section 6 or section 24 of the General Clauses Act, 1897 (X of 1897),--
(a) .................................. ...........................
(b) where a return of income if filed after the commencement of this Ordinance otherwise than in pursuance of any notice under section 34 of the repealed Act, by any person for any assessment year ending on or before the thirtieth day of June, 1979, the assessment of the person for that year shall be made in accordance with the procedure specified in this Ordinance;
(c) ..................................................
(d) in making any assessment for any year ending on or before the thirtieth day of June, 1979, the provisions of the repealed Act relating to the computation of total income and the tax payable shall apply as if this Ordinance had not come into force.
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From bare perusal of clause (d) it appears that it deals with those assessments which are regarding any year ending on or before 30th day of June, 1979, but it makes the provisions of repealed Act applicable which are relating to the computation of total income anti the tax payable. In other words, it means that at the time of computing total income and the tax payable thereon an Income-tax Officer is required to keep into consideration the rate of tax and those deductions etc., which he was required to make from the income declared which were permissible under the repealed Act. Moreover, it deals with those cases in which an assessment is to be made for any year ending on or before the 30th day of June, 1979. If we read the definition of assessment as contained in section 2(7) of the Ordinance, it appears that the word assessment includes re-assessment and additional assessment. As such, any type of assessments which, are contemplated by clause (d) may be either the original assessment or revised or additional assessment made pursuant to an appellate or revisional order. However, this caluse does not deal with the point of time at which such return for that assessment year d was filed. Clause (b), on the other hand, squarely deals with this issue. It makes the repealed Act applicable to these returns, which are filed after the commencement of this Ordinance but, it is important to note, if they are filed in pursuance of any notice issued under section 34 of the repealed Act and not to those returns, which are filed after the commencement of this Ordinance voluntarily. With this discussion in mind when I revert to the facts of these appeals it appears that all the returns were filed, as is clear from the impugned order, much after the promulgation of the Income-tax Ordinance. I am, therefore, of the view that submission of Mr. Muhammad Farid that in view of clause (b) of subsection (2) of section 166, the provisions of the Ordinance apply to all the four appeals, carries much weight and, in my humble opinion the provisions of section 134 of the Ordinance are applicable in the case of the appellant regarding all the assessment years.
6. Now when I peruse section 134(1) of the Ordinance, it appears that if an assessee wants to file an appeal to the Tribunal, he must fulfil the following conditions:--
(i) The order appealed against must be by an Appellate Assistant Commissioner under section 111 or 132 or subsection (2) of section 148, or under section 156, or"
(ii) it should be an order recorded by an Inspecting Assistant Commissioner under section 66-A, and
(iii) whether it is an order recorded by Appellate Assistant Commissioner or Inspecting Assistant Commissioner under sections mentioned above, it must--
(a) enhance the assessment,
(b) reduce a refund, or
(c) otherwise increase the liability of the assessee.
7. In these appeals neither the Inspecting Assistant Commissioner has enhanced the assessment, nor reduced the refund, nor otherwise increased the liability of the appellant. On the other hand, the learned Inspecting Assistant Commissioner has cancelled all the assessments for the reason that the interest income declared by the appellant was the income of his wife and should be taxed accordingly. Thus, the learned Inspecting Assistant Commissioner has, in effect, reduced the tax liability of the appellant. As such, these appeals, as submitted by Mr. Muhammad Farid, the learned Departmental Representative, are not maintainable in law-.
8. Mr. Sirajul Haq Memon, the learned counsel for the appellant, vehemently submitted before me that the learned Inspecting Assistant Commissioner committed serious error in law when he recorded the impugned order after ignoring the provisions of section 83(4) of the Ordinance. They are as under:--
"83. Income from revocable transfer of assets etc.--
(4) All income derived from any asset transferred by an assessee directly or indirectly to--
(a) his spouse, otherwise than by way of gift or for adequate consideration, or in connection with an agreement to live apart; or
(b) any minor child of the assessee otherwise than by way of gift or for adequate consideration; or
(c) any person for the benefit of his spouse or any minor child, or both, otherwise than by way of gift or for adequate consideration,
shall be chargeable to tax as the income of the transferor, and shall be included in his total income.
(5) For the purpose of this section.--
(a) a transfer shall be deemed to be revocable if--
(i) it contains any provision for the re-transfer directly or indirectly of the whole or any part of the assets to transferor, or
(ii) it gives, in any way, the transferor a right to resume power, directly or indirectly over the whole or any part of the assets;
(b) "transfer" includes any indisposition, settlement, trust, covenant, agreement or arrangement; and
(c) "minor child" does not include a married daughter.",
Mr. Sirajul Haq submitted before me that all the F.D.Rs. were purchased by the appellant out of his own funds and his wife was merely a Benami-holder thereof. 1 am afraid there is no evidence available on' record to support this submission of learned counsel for the appellant. It is true that purchase of an asset directly in name of a spouse or child may be deemed as a transfer of asset in view of the Madras High Court ruling reported as Kader Batcha v. State of Madras (1968) 68 ITR 738. It is also true that the word "transfer" as used in subsection (4) and as defined by clause (b) of subsection (5) of section 83 of the Ordinance does not carry the meaning of transfer as contemplated by Transfer of Property Act and purchasing of an asset in the name of the wife of the appellant could be deemed to be an "arrangement" which is included within the definition of word "transfer" as used in clause (b) of subsection (5). Please-see Jaiswal v. C.I.T. (1981) 131) 1 1' It 643 S.1' But, unfortunately, there is no evidence on record to support the contention of Mr. Sirajul flag Memon that the F. D. Rs were purchased by the appellant out of his own funds but they stood in the name of his wife and, as such, the income accruing from them is chargeable to tax as the income of the appellant himself. The learned counsel for the appellant in fact wants a declaration from us that the appellant is the real owner of the F. D. its. which we cannot, under the facts and circumstances of these appeals, grant to hire. If the appellant has any dispute regarding his right, title or interest to the F. D. R., he could be well advised to go to civil Court to seek a declaration to that effect. As far as I am concerned, I do not think that I have any jurisdiction to grant such relief to Mr. Sirajul Haq
9. The learned counsel for the appellant expressed his astonishment on the wisdom of the Department regarding the taxability of the interest income. He has submitted that the interest income in the hands of the wife has been ordered to be deleted in appeal on one hand, while oil the other the learned Inspecting Assistant Commissioner has cancelled all the assessments, thus thereby again excluding the interest income to be taxed in his hands. Indeed the circumstances of these appeals are peculiar but as the law stands I feel very much constrained to uphold the preliminary objection .of Mr. Muhammad Farid, the learned Departmental Representative. However, before parting with these appeals let me point out that the provisions of section 134(1) of the Ordinance requires to be amended on the pattern of subsection (1) of section 253 of tire Indian Income-tax Act, 1961 which is as under:--
--(1) Any assessee aggrieved by any of the following orders may appeal to the Appellate Tribunal against such order--
(a) an order passed by an Appellate Assistant Commissioner or, as the case may be, the Commissioner (Appeals) under subsection (2) of section 131, section 154, section. 250, or section 271, section 271-A, or section 272-A; or
(b) an order passed by an Inspecting Assistant Commissioner under section 154; or
(c) an order passed by a Commissioner under section 263 or under section 272-A or under section 285-A or an order passed by him under section 154 amending his order under section 263. "
From perusal of the abovequoted subsections of the Indian Act, it appears that the right of appeal has been given to an assessee who feels aggrieved by any of the orders passed by either the Appellate Assistant Commissioner or Inspecting Assistant Commissioner, or Commissioner under section mentioned in clause (a), (b) and (c), as reproduced above. In our repealed Income-tax Act, we had also worded its section 33 in quite wide terms. Had I been exercising my jurisdiction under section 33, or under section 253(1) of the Indian Act, I would have turned down the preliminary objection of Mr Muhammad Farid, the learned Departmental Representative and, after holding the order of Inspecting Assistant Commissioner recorded in contravention of section 83(4) of the Ordinance, would have set aside his order and sent the matter back to Income-tax Officer to make necessary investigation regarding the appellant's allegations about the F.D.Rs. and then to frame-assessment de novo.
In view of discussion made above I find all the four appeals not maintainable in law and they are rejected on preliminary ground alone.
M.B.A./362/T Order accordingly.
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