{"id":80857,"date":"2001-01-24T00:00:00","date_gmt":"2001-01-23T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/ms-oxford-university-press-vs-commissioner-of-income-tax-on-24-january-2001"},"modified":"2016-03-20T14:38:16","modified_gmt":"2016-03-20T09:08:16","slug":"ms-oxford-university-press-vs-commissioner-of-income-tax-on-24-january-2001","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/ms-oxford-university-press-vs-commissioner-of-income-tax-on-24-january-2001","title":{"rendered":"M\/S Oxford University Press vs Commissioner Of Income-Tax on 24 January, 2001"},"content":{"rendered":"
Supreme Court of India<\/div>\n
M\/S Oxford University Press vs Commissioner Of Income-Tax on 24 January, 2001<\/div>\n
Author: Bharucha<\/div>\n
Bench: S.P.Bharucha<\/div>\n
           CASE NO.:\nAppeal (civil) 533  of  1997\nAppeal (civil)\t534\t of  1997\nAppeal (civil)\t4406\t of  1997\nAppeal (civil)\t7275\t of  1999\n\n\n\nPETITIONER:\nM\/S OXFORD UNIVERSITY PRESS\n\n\tVs.\n\nRESPONDENT:\nCOMMISSIONER OF INCOME-TAX\n\nDATE OF JUDGMENT:\t24\/01\/2001\n\nBENCH:\nS.P.Bharucha\n\n\n\n\nJUDGMENT:\n<\/pre>\n
L…..I………T…….T…….T…….T…….T…….T..J<\/p>\n
      J U D G M E N T<\/p>\n
      Bharucha, J.\n<\/p>\n
      These  appeals  by  special  leave are  filed  by\t the
\nassessee.   They impugn the correctness of the judgment\t and
\norder  of the High Court at Bombay dated 21st December, 1995
\nin  respect  of the Assessment Year 1976-77  and  subsequent
\norders\tof the High Court following the aforestated judgment
\nfor the Assessment Years 1972-73, 1973-74, 1974-75, 1977-78,
\n1979-80\t  &   1983-84.\t  The\tquestion  that\t arose\t for
\nconsideration  in references to the High Court under Section
\n256(1) of the Income Tax Act, 1961 read :\n<\/p>\n
      Whether  on the facts and in the circumstances of the
\ncase  the  Tribunal  was justified in  holding\tthat  Oxford
\nUniversity   Press,   Bombay,  which  is  part\t of   Oxford
\nUniversity, is exempt under section 10(22) of the Income Tax
\nAct, 1961 ?\n<\/p>\n
      The  question  was answered by the High Court  in\t the
\nnegative and in favour of the Revenue.\n<\/p>\n
      The  assessee  is\t a branch of the  Oxford  University
\nPress, which, as the question itself notes, is a part of the
\nUniversity  of\tOxford in the United Kingdom.  The  assessee
\npublishes  books  and carries on similar business in  India.
\nIt  was treated as a non resident company under the terms of
\na  Notification\t issued by the Central Board of\t Revenue  on
\n31st  July,  1954  at its request from the  Assessment\tYear
\n1952-53\t onwards.   For\t the  Assessment  Year\t1976-77\t the
\nassessee returned an income of Rs.  19.94 lakhs, but, in the
\ncourse\tof the assessment proceedings before the  Income-tax
\nOfficer,  it  claimed  that,  as  it was  a  branch  of\t the
\nUniversity  of Oxford, the same was exempt from the  payment
\nof  income  tax by virtue of the provisions of\tSection\t 10,
\nclause\t(22)  of the Income Tax Act, 1961.  The Income-\t tax
\nOfficer\t rejected  the contention and brought the income  to
\ntax.  The Commissioner (Appeals), in the appeal filed by the
\nassessee,  overturned  the  assessment\t by  the  Income-tax
\nOfficer.   Aggrieved  by  the\torder  of  the\tCommissioner
\n(Appeals),  the Revenue approached the Income Tax  Appellate
\nTribunal.   The Tribunal dismissed the appeal.\tArising\t out
\nof  the\t judgment  and order of the Tribunal,  the  question
\naforestated was referred to the High Court.\n<\/p>\n
      The  High Court stated in the judgment and order under
\nchallenge  that,  admittedly,  the assessee was\t the  Oxford
\nUniversity Press and not the University of Oxford, but there
\nwas  a\tfinding\t of  the Tribunal to  the  effect  that\t the
\nassessee  was  a part of the University of Oxford.   In\t its
\nview,  what  was necessary for availing the benefit  of\t the
\nexemption under Section 10(22) was that the income should be
\nthe  income  of an University or an educational\t institution
\nexisting  solely  for educational purposes and not  for\t the
\npurposes  of  profit.  In the context and setting of  clause
\n(22), the word existing in the expression existing solely
\nfor educational purposes and not for the purposes of profit
\nmeant  and  referred to the existence of such University  or
\ninstitution  solely  for educational purposes in India.\t  In
\nother  words,  a University or an  educational\tinstitution,
\nwhether\t established  in India or abroad, had to retain\t the
\ncharacter  of a University or an educational institution  in
\nIndia,\tand the income in respect of which the exemption was
\nclaimed\t had to be income derived by it in its capacity as a
\nUniversity  or\tan educational institution.  If it  did\t not
\ncarry  on  its\tactivities as a\t University  or\t educational
\ninstitution  in\t India,\t it  could  not\t be  regarded  as  a
\nUniversity  or\teducational institution existing solely\t for
\neducational  purposes  and, hence, the income derived by  it
\nfrom  any  other activities would not qualify for  exemption
\nunder\tSection\t 10(22).   The\t assessee  was\tthe   Oxford
\nUniversity  Press  and\tnot the University of  Oxford.\t The
\nUniversity of Oxford did not exist in India nor did it carry
\non the activities of a University in India.  What existed in
\nIndia  was  the Oxford University Press.  The only  activity
\ncarried\t on  by the Press, which was the assessee, in  India
\nwas  the  activity  of\tprinting and  publishing  books\t and
\nselling\t them as well as publications of other publishers to
\nearn  profit.\tThis  activity amounted to carrying  on\t the
\nbusiness  of selling or supplying books for profit.   Income
\nmade  therefrom\t could\tnot be regarded as the income  of  a
\nUniversity  existing solely for educational purposes  merely
\nbecause\t the assessee claimed to be a part of the University
\nof  Oxford,  which did not exist in India.  The\t High  Court
\nadded,\tIf  it\tdoes  not  exist  as  a\t University  or\t an
\neducational  institution  solely for such purposes and\tdoes
\nnot  carry  on\tthe primary activities of  a  University  or
\neducational  institution  but  merely runs the\tbusiness  of
\npress in India for printing and publishing books and selling
\nand  supplying the same as well as books published by  other
\npublishers  for the purpose of profit, it cannot be held  to
\nbe  a  University within the meaning of section 10(22)\tof
\nthe  Act  merely by reason of the fact that it is run  by  a
\nUniversity  existing outside India for educational  purposes
\nor  that it is a part of such University.   If the case of
\nthe  assessee is that in the true sense of the term it is  a
\npart  and  parcel  of  the  Oxford  University\tand  has  no
\nindependent  existence of its own and all its income is\t the
\nincome\tof  the\t said  University, the\tassessee  for  the
\npurpose\t of  the Income-tax Act would have been the  Oxford
\nUniversity  and not the Press.\tThe Press, as an assessee
\nmight  have  been entitled to claim exemption in respect  of
\nits  income  under  Section 10(22) of the Act  if  it  could
\nestablish  that\t the  income  is the income  of\t the  Oxford
\nUniversity  which existed solely for educational  purposes.
\nOn  this  basis, the High Court held against  the  assessee.
\nSection 10, clause (22) reads thus:\n<\/p>\n
      10.  Income not included in total income<\/p>\n
      In  computing  the total income of a previous year  of
\nany  person, any income falling within any of the  following
\nclauses shall not be included –\n<\/p>\n
      (22)  any income of a university or other\t educational
\ninstitution,  existing\tsolely for educational purposes\t and
\nnot for purposes of profit.\n<\/p>\n
      By  reason  of  Section  10(22),\t any  income  of   a
\nUniversity or other educational institution, existing solely
\nfor  educational purposes and not for purposes of profit, is
\nnot  includible\t in its total income.  A University  is\t the
\ncreation  of  a\t Charter  or  a\t statute.   It\tis   created
\nexclusively  for  educational purposes, and not for  profit.
\nAn  educational institution, while it may impart  education,
\nmay yet have a profit motive.  Strictly speaking, therefore,
\nthe phrase existing solely for educational purposes and not
\nfor  the  purposes of profit in clause (22) qualifies  only
\nthe  words other educational institution and not the words
\na  University.\t But this strict interpretation is  of\tno
\ngreat  account\tfor  the  purposes of  this  case,  and\t the
\nexpression  may\t be read to qualify both a University  and
\nother  educational  institution.   For\t the  purposes\tof
\nobtaining  the\texemption under clause (22)  the  University
\nmust  be  existing solely for educational purposes and\tnot
\nfor  the  purposes of profit.  What this means is that\tthe
\nsole purpose of a University must be to impart education and
\nnot  at\t all  to make profit.  The word\t existing  in  the
\ncontext\t means\tbeing.\tIt has no locational  sense.   The
\nclause\tdoes  not say existing in India and the words  in
\nIndia  cannot be read into it.\tThe clause does not require
\nthat the University must impart education in India before it
\ncan qualify for exemption thereunder.  The High Court was in
\nerror in interpreting the clause differently.\n<\/p>\n
      The  High Court failed to appreciate that the assessee
\nwas  a part of the University of Oxford, as the Tribunal had
\nfound  and  the question before it indicated, and  that\t the
\nincome\tthat  was  under consideration for  assessment\twas,
\ntherefore,  the\t income\t of the University of  Oxford.\t The
\nperson\tthat  was being taxed was not and could not  be\t a
\nbranch\tof  the University of Oxford;  it could only be\t the
\nUniversity  of\tOxford.\t That the University of Oxford is  a
\nhallowed  institution of learning that exists, or is, solely
\nfor  educational purposes is not, and cannot reasonably\t be,
\nin  dispute.   That the income is derived by  the  printing,
\npublishing  and selling of books has no relevance because it
\nis  still  the\tincome\tof an  University  that\t exists\t for
\neducational purposes.\n<\/p>\n
      It  is  trite  law and now needs no authority  that  a
\ntaxing\tstatute must be read as it stands:  no words may  be
\nadded,\tno  words subtracted.  Further, learned counsel\t for
\nthe assessee was right in pointing out that where Parliament
\nhad intended the exemption under Section 10 to be limited in
\nany  way to the territory of India it had been assiduous  in
\nso stating;  (see, for example, clauses 20A, 22B, 23, 24, 26
\nand 29 thereof).\n<\/p>\n
      It  was  submitted by learned counsel for the  Revenue
\nthat  the word University used in Section 10(22) should be
\nread  in the manner in which it was defined in Section\t2(f)
\nof  the\t University Grants Commission Act, 1956, that is  to
\nsay,  to mean a University established or incorporated by or
\nunder  a  Central Act, a Provincial Act or a State Act;\t  in
\nother  words,  to  mean\t an Indian University.\t It  is\t not
\npermissible to read the definition of a word in one Act into
\nanother\t Act  unless the latter Act so requires.  It is\t all
\nthe more difficult when the University Grants Commission Act
\ncan  by its very purpose, namely, to make provision for\t the
\ncoordination  and determination of standards in Universities
\nand  for  that\tpurpose\t to establish  a  University  Grants
\nCommission, apply only to Universities in India.  Further, a
\nclause\tidentical  to clause (22) was inserted\tinto  Indian
\nIncome\tTax  Act, 1922 by a notification dated\t21st  March,
\n1922  and  that clause in the 1922 Act was in terms  brought
\ninto the 1962 Act.  A definition in an Act of 1956 cannot be
\nread  to  limit the scope of a word first used in an Act  of
\n1922 and then incorporated in an Act of 1962.\n<\/p>\n
      Learned counsel for the Revenue then drew attention to
\nSection\t 10(22A), which reads thus :  (22A) – any income of
\na  hospital  or\t other\tinstitution for\t the  reception\t and
\ntreatment  of  persons\tsuffering  from\t illness  or  mental
\ndefectiveness  or for the reception and treatment of persons
\nduring\tconvalescence  or  of\tpersons\t requiring   medical
\nattention   or\t rehabilitation,     existing\tsolely\t for
\nphilanthropic purposes and not for purposes of profit.\n<\/p>\n
      In  the submission of learned counsel for the  Revenue
\nclauses (22) and (22A) could not have been intended to grant
\nthe  exemption for the benefit of children and the sick\t and
\ninfirm\toutside India.\tParliament, in his submission, would
\nnot  forego tax revenue for the benefit of educating  people
\nin  the\t University  of\t Oxford in the\tUnited\tKingdom.   A
\nconstruction  that  would  enable  this to  happen  was,  he
\ncontended,  manifestly\tunreasonable  and absurd  and  could
\nnever  have been intended.  It was, therefore, necessary  to
\nread  clause  (22)  as\tapplying only  to  Universities\t and
\neducational  institutions  which  existed in  India  or,  at
\nleast, imparted education in India.  Our attention was drawn
\nby  learned counsel for the Revenue to the judgments of this
\nCourt in K.P.  Varghese vs.  Income Tax Officer, Ernakulam &
\nAnr.,<\/a>  [1981(4)\t SCC  173] and Commissioner of\tIncome\tTax,
\nBangalore  vs.\tJ.H.  Gotla, Yadagiri,<\/a> [1985(4) SCC 343]  in
\nsupport of the contention.\n<\/p>\n
      In  Vargheses case, the assessee owned a house  which
\nhe  had\t purchased in 1958 for the price of  Rs.16,500.\t  In
\n1965  he  sold the house for the same price of Rs.16,500  to
\nhis  daughter-in-law and five children.\t It was not disputed
\nthat  this sale was an honest and bona fide transaction\t and
\nthat  the  consideration  was in fact  Rs.16,500.   However,
\nafter  completion of the assessment for the year 1966-67  in
\nthe  normal  course  in this manner, the  I.T.O.   issued  a
\nnotice\tto re-open the assessment on the basis that  Section
\n52(2)  of the 1962 Act was attracted because the fair market
\nvalue  of  the\tproperty  as on the  date  of  the  transfer
\nexceeded  the  consideration of Rs.16,500 by not  less\tthan
\n15%.   The  I.T.O.  proposed, accordingly, to fix  the\tfair
\nmarket\tvalue  of  the\thouse at Rs.65,000  and\t assess\t the
\ndifference of Rs.48,500 as capital gains in the hands of the
\nassessee.   The\t assessee  filed a writ\t petition.   It\t was
\nallowed,  but, in appeal, the Full Bench of the Kerala\tHigh
\nCourt  accepted\t as  correct  the ITOs\tview.\tThis  Court
\nreversed  the  Full  Bench  decision, and it  said  that  if
\nsub-section  (2)  of Section 52 was literally construed,  as
\napplying  to cases where the consideration in respect of the
\ntransfer   was\t correctly  declared   and  there   was\t  no
\nunderstatement\tof consideration, it would result in amounts
\nbeing  taxed  which had neither accrued to the assessee\t nor
\nwere  received\tby him and which from no view point can\t be
\nrationally  construed as capital gains or any other type  of
\nincome.\t  It is a well settled rule of construction that the
\nCourt  should  as  far as possible avoid  that\tconstruction
\nwhich  attributes irrationality to the legislature. It\twas
\nalso found that, so construed, sub-section (2) was violative
\nof  the Constitution and the Court  must obviously prefer a
\nconstruction   which   renders\t the   statutory   provision
\nconstitutionally  valid rather than that makes it void. The
\nCourt  said in the course of the judgment, It is now a well
\nsettled\t rule  of construction that where the plain  literal
\ninterpretation\t of  a\tstatutory   provision\tproduces   a
\nmanifestly  absurd and unjust result which could never\thave
\nbeen  intended by the legislature, the Court may modify\t the
\nlanguage  used by the legislature or even do some violence
\nto  it,\t so  as\t to achieve the\t obvious  intention  of\t the
\nlegislature   and   produce    a   rational   construction.
\nAccordingly, the Court read into Section 52(2) the condition
\nthat  it  would\t apply\tonly  where  the  consideration\t for
\ntransfer was understated and it would have no application in
\nthe  case of a bona fide transaction when the full value  of
\nthe consideration was correctly declared by the assessee.\n<\/p>\n
      In  Gotlas case, a strict and literal construction of
\nSection 16(3) read with Section 24(2) of the 1962 Act led to
\nthe  conclusion\t that  where the wife or  minor\t child\twere
\ncarrying on a business, while the right to carry forward the
\nloss  in the business would be available to the wife or\t the
\nminor  child  if  they themselves were assessed,  the  right
\nwould  be  lost if the individual in whose total income\t the
\nloss  was to be included was not permitted to carry  forward
\nthe  loss  under  Section 24(2).  The Court held  that\tthis
\ncould  not  have  been the intention of\t Parliament.   If  a
\nstrict literal construction led to an absurd result, i.e., a
\nresult\tnot  intended to be subserved by the object  of\t the
\nlegislation,  and if another construction was possible apart
\nfrom the strict literal construction, then that construction
\nshould be preferred to the strict literal construction.\t The
\nCourt,\ttherefore, held, on a consideration of the scheme of
\nthe  Act and the relevant provisions, that the income of the
\nwife and the minor children included in the assessees total
\nincome\tunder  Section 16(3) should be regarded as  business
\nincome derived from business carried on by the assessee and,
\nin  that view, the assessee was entitled to set off his loss
\ncarried forward from the previous years.\n<\/p>\n
      Now,  learned counsels submission is that\t Parliament
\ncould  never  have  intended to forego tax revenue  for\t the
\npurpose\t of  educating\tpeople\t outside  India;   this\t was
\nmanifestly  unreasonable  and absurd and, therefore,  clause
\n(22)  should  be  so  read   as\t applying  to\tUniversities
\nestablished  in\t India,\t or at least  providing\t educational
\nfacilities    in    India.     I   find\t   no\t unjustness,
\nunreasonableness,   irrationality   or\t absurdity  in\t the
\nprovisions  of clause (22).  It does not strike me as  being
\nbeyond\tthe bounds of possibility that Parliament should  be
\nwilling to forego a very small percentage of tax revenue for
\nthe  purposes  of education, even though it might  mean\t the
\neducation  of  people outside India, if that  education\t was
\nbeing\tprovided  by  a\t  University  or  other\t educational
\ninstitution  whose sole purpose was to provide education and
\nnot  at\t all  to make a profit.\t I do not  think  Parliament
\ncould  not  possibly have meant what clause (22) so  plainly
\nsays.\tI see, therefore, no reason to read clause (22) in a
\nfashion that is not literal.\n<\/p>\n
      It  should  be noticed that clause (22A),\t which\talso
\ngives  an  exemption without any limitation as to  location,
\nwas  introduced into Section 10 in 1970.  It cannot be\tthat
\nParliament  yet again failed to express its true intendment.
\nIf  Parliament\thad  meant to provide an  exemption  with  a
\nlocational  limitation in clause (22A) it would have made it
\nclear, and it would have amended clause (22).\n<\/p>\n
      The  judgment and order under challenge cannot  stand,
\nand  the  question  quoted  above must be  answered  in\t the
\naffirmative  and in favour of the assessee.  The appeals are
\nallowed accordingly.  No order as to costs.<\/p>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India M\/S Oxford University Press vs Commissioner Of Income-Tax on 24 January, 2001 Author: Bharucha Bench: S.P.Bharucha CASE NO.: Appeal (civil) 533 of 1997 Appeal (civil) 534 of 1997 Appeal (civil) 4406 of 1997 Appeal (civil) 7275 of 1999 PETITIONER: M\/S OXFORD UNIVERSITY PRESS Vs. RESPONDENT: COMMISSIONER OF INCOME-TAX DATE OF JUDGMENT: […]<\/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":[30],"tags":[],"class_list":["post-80857","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nM\/S Oxford University Press vs Commissioner Of Income-Tax on 24 January, 2001 - 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\/ms-oxford-university-press-vs-commissioner-of-income-tax-on-24-january-2001\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"M\/S Oxford University Press vs Commissioner Of Income-Tax on 24 January, 2001 - 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