{"id":257256,"date":"2011-07-27T00:00:00","date_gmt":"2011-07-26T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/anil-batra-vs-chief-commissiioner-of-income-tax-on-27-july-2011"},"modified":"2016-02-06T19:49:57","modified_gmt":"2016-02-06T14:19:57","slug":"anil-batra-vs-chief-commissiioner-of-income-tax-on-27-july-2011","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/anil-batra-vs-chief-commissiioner-of-income-tax-on-27-july-2011","title":{"rendered":"Anil Batra vs Chief Commissiioner Of Income Tax on 27 July, 2011"},"content":{"rendered":"
Delhi High Court<\/div>\n
Anil Batra vs Chief Commissiioner Of Income Tax on 27 July, 2011<\/div>\n
Author: M. L. Mehta<\/div>\n
*     IN THE HIGH COURT OF DELHI AT NEW DELHI\n\n+                    W.P.(C) No. 4673\/2010\n\n                                          Reserved On: JULY 05, 2011\n%                                Judgment Delivered On: JULY 27, 2011\n\nANIL BATRA                                             ... Petitioner\n                         Through:   Mr. Viraj R. Datar, Advocate for the\n                                    petitioner.\n\n                              Versus\n\n\nCHIEF COMMISSIIONER OF INCOME TAX         ... Respondent\n                  Through: Mr. Anupam Tripathi, Standing\n                           Senior Counsel with Ms. Anusha\n                           Singh,   Advocates   for   the\n                           respondent.\n\nCORAM:\nHON'BLE MR. JUSTICE A.K.SIKRI\nHON'BLE MR. JUSTICE M.L.MEHTA\n\n\n1. Whether the Reporters of local papers\n   may be allowed to see the judgment?         Yes\n\n2. To be referred to Reporter or not?          Yes\n\n3. Whether the judgment should be              Yes\n   reported in the Digest?\n\n\n\nM.L.MEHTA, J.\n<\/pre>\n
1.    The Petitioner is the Managing Director of M\/s Anil Batra and<\/p>\n
Associates Private Limited. During the AY 1982-83, tax deducted at<\/p>\n
source by the company was deposited beyond the period prescribed by<\/p>\n
law. Similarly, during AY 1983-84 and 1984-85 also, the company<\/p>\n
deposited the tax beyond the period prescribed by law. That being so,<\/p>\n
WP(C) No.4673\/2010                                           Page 1 of 10<\/span>
\n the Income Tax Department filed complaints dated 27.03.1986 against<\/p>\n
the Company & Directors under section 276B<\/a> of Income Tax Act before<\/p>\n
the Court of CMM for all the three Assessment Years. The complaint for<\/p>\n
the Assessment Year 1982-83 is still at trial stage. As regards the<\/p>\n
complaints for the years 1983-84 and 1984-85, the Ld. ACMM awarded<\/p>\n
simple imprisonment of three months for the two Directors of the<\/p>\n
company and a fine of ` 7,000\/- on the company and its two directors.<\/p>\n
Against this order, the Department has filed a revision petition for<\/p>\n
enhancement of sentence, and the petitioner has filed appeal against<\/p>\n
the conviction, both of which are pending before the Addl. Session’s<\/p>\n
Judge, Delhi.\n<\/p>\n
\n
2.    On 31.05.1986, (two months after the complaint was filed by the<\/p>\n
Income Tax Department) the petitioner moved an application before the<\/p>\n
department for compounding of offence under section 276B<\/a>, which was<\/p>\n
rejected by the CBDT vide letter dated 16.01.1987.<\/p>\n
3.    On 29.07.2003, the CBDT issued a Circular whereby Guidelines for<\/p>\n
Compounding were reviewed in the light of past experiences and future<\/p>\n
needs. The petitioner received a letter dated 25.09.2003 and copy of<\/p>\n
guidelines. The petitioner replied the same vide letter dated 29.09.2003,<\/p>\n
expressing his willingness to compound the offence and requesting the<\/p>\n
Department to communicate the amount of compounding fees so that<\/p>\n
the same could be deposited at the earliest. The petitioner, however,<\/p>\n
received no reply from the department in this regard.<\/p>\n
WP(C) No.4673\/2010                                            Page 2 of 10<\/span>\n<\/p>\n
 4.    The petitioner, through its Chartered Accountants, sent a detailed<\/p>\n
proposal dated 17.11.2003 to the Department after calculating the<\/p>\n
approximate Compounding Fee applicable for each of the three years.<\/p>\n
Again, the petitioner received no reply from the Department.<\/p>\n
5.    The petitioner thereafter filed two petitions before this court,<\/p>\n
(which were clubbed together), praying inter-alia for staying of appeal<\/p>\n
proceedings pending before the Addl. Session’s Judge, subject to the<\/p>\n
outcome of the disposal of the petitioner’s compounding petition before<\/p>\n
the Income Tax Department. This court disposed of the same vide order<\/p>\n
dated 28.07.2005 in the following terms:\n<\/p>\n
\n
             “In view of the same, petitioner is directed to appear
\n             before Commissioner of Income-Tax, Delhi-I,
\n             C.R.Building on 22.08.2005 or any other date, that
\n             may be convenient to the Commissioner, who shall
\n             adjudicate as to what amount is liable to be
\n             deposited by the petitioner, and pass appropriate
\n             orders regarding compounding of the offence.
\n             Petitioner shall deposit the balance amount within
\n             one week thereafter. Learned counsel for the
\n             respondent submits that petitioner be directed to
\n             deposit the amount which according to him is due
\n             and payable. Ordered accordingly.”\n<\/p><\/blockquote>\n
6.    Armed with this order, the petitioner through his representative<\/p>\n
approached     the   competent   authority   and   put   up   his    case     for<\/p>\n
compounding of offences of all the three assessment years. However,<\/p>\n
the competent authority vide its detailed order dated 30.01.2006<\/p>\n
rejected the compounding petition of the petitioner. While doing so,<\/p>\n
the competent authority reasoned as under:\n<\/p>\n
\nWP(C) No.4673\/2010                                                  Page 3 of 10<\/span>\n<\/p>\n
              “It will be pertinent here to mention that the
\n             assessee has been convicted for the A.Y.’s 1983-
\n             84, an 1984-85 by the Ld. ACMM who has awarded
\n             simple imprisonment of three months for the two
\n             Directors and a fine of `7,000\/- on the company
\n             and the two Directors. The Department has filed a
\n             revision petition before the Hon’ble Sessions Judge,
\n             Delhi requesting for enhancement of the sentence.
\n             The assessee has also filed appeals before the
\n             Hon’ble Sessions Judge against the conviction.
\n             These petitions are still pending for disposal. The
\n             complaint filed for A.Y. 1982-83 is still at the trial
\n             stage.\n<\/p><\/blockquote>\n
             After considering all the facts and materials of the
\n             case and the submission made by the counsel for
\n             the assessee I find that there is no material change
\n             in the facts of the case, since the disposal of earlier
\n             applications by the CBDT as well as the Chief
\n             Commissioner of Income Tax Delhi-I. Moreover, it
\n             is to be noted that the assessee has already been
\n             convicted for A.Y.’s 1983-84 and 1984-85 by a
\n             competent Court and the department is already in
\n             revision before a higher court for enhancement of
\n             punishment. The offence committed in the period
\n             relevant to AY 1982-83 is of similar nature as for
\n             other two years and the case is already under trial.
\n             In such circumstances in the interest of justice as
\n             well as judicial propriety it will not be prudent on
\n             my part to compound these offence at this stage.
\n             Therefore, the compounding petition of the
\n             assessee for all the three years is, hereby
\n             rejected.”\n<\/p><\/blockquote>\n
7.    The petitioner has impugned the order dated 30.01.2006 of the<\/p>\n
CCIT. Learned counsel for the petitioner contends that the CCIT was<\/p>\n
under an obligation to compound the offence in view of the order<\/p>\n
dated 28.07.2005 passed by this Court directing the CIT to adjudicate<\/p>\n
as to what amount is payable to be deposited by the petitioner. He<\/p>\n
also contends that in view of the amended guidelines, the offences<\/p>\n
WP(C) No.4673\/2010                                              Page 4 of 10<\/span>
\n being technical in nature were eligible for compounding.              He also<\/p>\n
contends that the proceedings for compounding of offence were<\/p>\n
proposed by the respondent itself vide its letter dated 25.09.2003.<\/p>\n
On the other hand, learned counsel appearing for the respondent<\/p>\n
submits that the offences were not compoundable since the<\/p>\n
complaints had already been filed against the petitioner and in two of<\/p>\n
those the petitioner stood convicted by the competent court.<\/p>\n
8.    With regard to the contention of the learned counsel for the<\/p>\n
petitioner that the CCIT has violated the order dated 28.07.2005 in<\/p>\n
failing to comply the terms and adjudicate as to the amount of<\/p>\n
compounding fee, it is seen that this order came to be passed by this<\/p>\n
Court on the submissions made by learned counsel for the petitioner<\/p>\n
that the TDS amount has already been deposited and that the<\/p>\n
petitioner was ready and willing to deposit any additional cost and<\/p>\n
compounding fee that may be imposed. That order cannot be<\/p>\n
construed to mean that the terms were to be effected and<\/p>\n
compounding          fee   charged,   even   if   the   offence     was     not<\/p>\n
compoundable.         The order also states that the Commissioner is to<\/p>\n
pass appropriate orders regarding compounding of the offence. This<\/p>\n
cannot be interpreted to mean that the Commissioner was directed to<\/p>\n
compound      the     offence   without   considering   if   the   same    was<\/p>\n
compoundable or not.\n<\/p>\n
\nWP(C) No.4673\/2010                                                 Page 5 of 10<\/span>\n<\/p>\n
 9.    After the existing guidelines dated 30.09.1994 for compounding<\/p>\n
of offences came to be revised vide notification dated 29.07.2003, a<\/p>\n
letter dated 25.09.2003 was issued by the ITO to the petitioner<\/p>\n
intimating the revised guidelines. Copy of the guidelines dated<\/p>\n
29.07.2003was also sent to the petitioner for perusal. The submission<\/p>\n
of the learned counsel that it was a proposal sent by the Department<\/p>\n
to compound the offence is untenable inasmuch as this was nothing<\/p>\n
more than intimation to the petitioner regarding revision of guidelines<\/p>\n
for compounding of offences. It is also noted here that the petitioner<\/p>\n
made his own estimate of the compounding fee and the interest and<\/p>\n
deposited `11,388, `58,208 and `29,215\/- on these counts for the<\/p>\n
three assessments years in question. The revised guidelines dated<\/p>\n
29.07.2003      mentioned       about    the   existing      guidelines     dated<\/p>\n
30.09.1994 and also the amendments made therein. Part A of the<\/p>\n
revised guidelines is related to procedural amendments which are<\/p>\n
reproduced hereunder:\n<\/p>\n
              “(A) Procedural Amendments:<\/p>\n
             (1)     under   the   existing    guidelines,    Technical
\n                     Offences (enlisted in para 2.2 of the said
\n                     Guidelines) are to be compounded by the
\n                     Chief   Commissioner      of   Income      Tax    or
\n                     Director General of Income Tax (Inv.) (as the
\n                     case may be), if following conditions are
\n                     collectively satisfied:\n<\/p><\/blockquote>\n
WP(C) No.4673\/2010                                                    Page 6 of 10<\/span><\/p>\n
              (i)     It is the first offence by the assessee.\n\n             (ii)    The compounding charges do not exceed `40\n                     lakh.\n\n<\/pre>\n
             (iii)   The offence is compounded only before the
\n                     filing of complaint.\n<\/p><\/blockquote>\n
             In all other cases, the technical offences as per
\n             existing Guidelines are to be compounded with the
\n             approval of the Board.<\/p><\/blockquote>\n
\n\n             In this regard, it has now been decided that\n\n             (a)     All types of cases relating to technical\n                     offences      are   to   be      compounded         by\n                     CCIT\/DGIT.\n\n             (b)     distinction    between        first    offence     and\n                     subsequent offence is removed; and\n\n             (c)     CCIT\/DGIT shall not reject an application for\n                     compounding of a technical offence, if all\n<\/pre>\n
                     conditions prescribed in the Guidelines are
\n                     satisfied.\n<\/p><\/blockquote>\n
             (II)    Para 5 (iii) of the existing Guidelines provides
\n                     that for compounding of substantive \/ non-
\n                     technical, in which the amount involved in
\n                     the offence exceeds `1 lakh, the Board shall
\n                     grant approval if Ministry of Law advises that
\n                     the chances of successful prosecution are not
\n                     good. This      requirement       of   referring   the
\n                     matter to the Ministry of Law has now been
\n                     done away with.”\n<\/p><\/blockquote>\n
WP(C) No.4673\/2010                                                      Page 7 of 10<\/span><\/p>\n
 10.   From the above, it may be seen that under the existing guidelines<\/p>\n
of 30.09.1994 (enlisted in para 2.2. of the said Guidelines), technical<\/p>\n
offences could be compounded by CCIT or DGIT if the three conditions<\/p>\n
were collectively satisfied namely (i) it is the first offence by the<\/p>\n
assessee; (ii) the compounding charge did not exceed `40 lac and (iii)<\/p>\n
the offence is compounded only before the filing of complaint. In all<\/p>\n
other cases, the technical offences as per the existing guidelines could<\/p>\n
be compounded with the approval of the Board. The amendment which<\/p>\n
came to be made in the revised guidelines of 29.07.2003 was to the<\/p>\n
effect that instead of the approval of the Board, all types of cases<\/p>\n
relating to technical offences could be compounded by CCIT and DGIT.<\/p>\n
Further distinction between first and subsequent offence was also<\/p>\n
removed. It was also specifically provided that CCIT\/DGIT shall not reject<\/p>\n
an application for compounding of technical offence, if all conditions<\/p>\n
prescribed in the guidelines are satisfied.\n<\/p>\n
\n
11.   Thus, it is seen that the condition that offences could be<\/p>\n
compounded only before the filing of the complaint remained unaltered<\/p>\n
in the revised guidelines of 29.07.2003. The amendment specifically<\/p>\n
stipulates that all the conditions prescribed are required to be satisfied<\/p>\n
for compounding of a technical offence. The learned counsel draws our<\/p>\n
attention to Clause-3 of the revised Guidelines of 29.07.2003 and<\/p>\n
submits that the compounding could be done even if the cases are<\/p>\n
pending in the Court. The Clause-3 thereof reads as under:<\/p>\n
WP(C) No.4673\/2010                                             Page 8 of 10<\/span>\n<\/p>\n
       “3.    Above amendments shall be applicable to future as well as<\/p>\n
             to cases pending at any stage. However, the offences<\/p>\n
             already compounded shall not be reconsidered.”\n<\/p><\/blockquote>\n
12.   The interpretation of the aforesaid Clause as presented by learned<\/p>\n
counsel is erroneous and misplaced. The plain and literal interpretation<\/p>\n
of the aforesaid Clause would only mean that the amendments made in<\/p>\n
the existing guidelines on 29.07.2003 would be applicable to the future<\/p>\n
as well as to the cases pending at any stage and that the offences<\/p>\n
already compounded shall not be reconsidered. In other words it would<\/p>\n
mean that it was the applicability of the amendments to the future as<\/p>\n
also to the cases pending and not that the compounding would be<\/p>\n
allowed even after the filing of the complaint or where the person has<\/p>\n
already been convicted by a competent court. The conditions stipulated<\/p>\n
for   compounding    of   a   technical   offence   being   very   clear    and<\/p>\n
unambiguous, compounding of such an offence was not permissible<\/p>\n
after filing of the complaint.      Undisputedly, three complaints have<\/p>\n
already been filed against the petitioner and in two of those, the<\/p>\n
petitioner stands convicted by the competent court. The revisions for<\/p>\n
enhancement of punishment have been filed by the Department and the<\/p>\n
appeals against the conviction have also been filed by the petitioner.<\/p>\n
Those revisions and the appeals are pending before the Appellate Court.<\/p>\n
One of the complaints is also still pending trial before the learned ACMM.<\/p>\n
That being the factual matrix, offence could not be said to be<\/p>\n
compoundable at this stage. In that fact situation, the competent
\nWP(C) No.4673\/2010                                                 Page 9 of 10<\/span>
\n authority was not bound to effect compounding in violation of the<\/p>\n
mandatory prohibitions prescribed therefor.\n<\/p>\n
\n
13.   In view of all this, no directions can be given by this Court to the<\/p>\n
competent authority to effect compromise or adjudicate compounding<\/p>\n
fee. The petition merits dismissal and is accordingly dismissed.<\/p>\n
                                                        M.L.MEHTA
\n                                                         (JUDGE)<\/p>\n
                                                       A.K. SIKRI
\n                                                        (JUDGE)<\/p>\n
JULY 27, 2011
\nawanish<\/p>\n
WP(C) No.4673\/2010                                             Page 10 of 10<\/span>\n <\/p>\n","protected":false},"excerpt":{"rendered":"
Delhi High Court Anil Batra vs Chief Commissiioner Of Income Tax on 27 July, 2011 Author: M. L. Mehta * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) No. 4673\/2010 Reserved On: JULY 05, 2011 % Judgment Delivered On: JULY 27, 2011 ANIL BATRA … Petitioner Through: Mr. Viraj R. Datar, Advocate […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[14,8],"tags":[],"class_list":["post-257256","post","type-post","status-publish","format-standard","hentry","category-delhi-high-court","category-high-court"],"yoast_head":"\nAnil Batra vs Chief Commissiioner Of Income Tax on 27 July, 2011 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/anil-batra-vs-chief-commissiioner-of-income-tax-on-27-july-2011\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Anil Batra vs Chief Commissiioner Of Income Tax on 27 July, 2011 - 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