{"id":97655,"date":"1986-10-30T00:00:00","date_gmt":"1986-10-29T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/income-tax-officer-vs-lalit-exhibitors-on-30-october-1986"},"modified":"2016-05-03T04:36:23","modified_gmt":"2016-05-02T23:06:23","slug":"income-tax-officer-vs-lalit-exhibitors-on-30-october-1986","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/income-tax-officer-vs-lalit-exhibitors-on-30-october-1986","title":{"rendered":"Income-Tax Officer vs Lalit Exhibitors on 30 October, 1986"},"content":{"rendered":"
Income Tax Appellate Tribunal – Jaipur<\/div>\n
Income-Tax Officer vs Lalit Exhibitors on 30 October, 1986<\/div>\n
Equivalent citations: 1987 20 ITD 239 JP<\/div>\n
Bench: H Ahluwalia, A Kalyanasundharam<\/div>\n<\/p>\n
<\/pre>\n
ORDER<\/p>\n
A. Kalyanasundharam, Accountant Member <\/p>\n
1. This is an appeal by the revenue in which the only issue is the cost of the assets introduced in the firm through one of the partners for purposes of allowing of depreciation.\n<\/p>\n
2. The facts of the case are a firm by name New Tej Talkies comprising of four partners was dissolved on 1-2-1979. Of the four partners, Mr. Narain M. Punjabi was interested to the extent of 50 per cent. Consequent to dissolution the other three partners were paid off their capital amount and also some amount for not claiming any further interest in the assets of the firm. On the same day Mr. Narain M. Punjabi who was also the partner in the assessee-firm entered into an agreement for bringing in the assets of the firm New Tej Talkies taken over by him as assets of the present assessee-firm. The claim of the assessee was the total value of the assets was to the tune of Rs. 3,40,958 on which depreciation was allowable in view of the fact that the assets so taken over had encumbrances in the shape of arrears of lease money payable to Rajasthan Government to the tune of Rs. 1,76,958,  liability  owing to exhibitors Rs. 39,000 and a sum of Rs. 1,25,000 payable\/creditable to the account of Mr. Narain M. Punjabi. The assessee gave the break-up of the figures of the assets as under :\n<\/p>\n
                                              Rs.\n<\/p><\/blockquote>\n
1.  Building                               80,958\n2.  Furnitures                             50,000\n3.  Electric fittings                      20,000\n4.  Machinery                            1,90,000\n                         Total           3,40,958\n\n \n\nThe assessee claimed depreciation at the aforesaid values.\n \n\n<\/pre>\n
3.  The ITO considered the claim of the assessee and was of the view that the cost of the assets as per Section 43, Explanation 3, of the  Income-tax Act, 1961 (‘the Act’) should be the cost less depreciation already  allowed to the earlier firm on which alone depreciation is allowable in the bands of the assessee-firm. The reply of the assessee to the ITO is as under :\n<\/p>\n
 That the case does not at all come within the ambit of Explanation 3 to Section 43, inasmuch as the transaction involved was a regular and genuine transaction made in the course of business and as a matter of business expediency. It is unwarranted to call it a ‘sham’ without proper evidence or material. On the contrary there is enough evidence and material to support the fact that this transaction is a genuine one entered into in the regular course of business. It may be stated that such arrangements are common in the film exhibition and cinema business.\n<\/p>\n
The ITO was not satisfied with the answer and, therefore, made a reference to the IAC, who vide his letter of 19-3-1982 advised the ITO that in view of Explanation 3 to Section 43 the cost on which depreciation will be allowed to the assessee-firm should be the actual cost to the earlier firm less depreciation allowed to that firm. The written down value on which depreciation was allowed ultimately was Rs. 76,931.\n<\/p>\n
4.   Aggrieved,    the   assessee   preferred   appeal   to   the   Commissioner (Appeals). The Commissioner (Appeals) in paragraph 1  had  reproduced the observation of the Tribunal  when the matter first travelled to  the Tribunal :\n<\/p>\n
 We have carefully considered the rival submissions. Shri Saxena has not controverted the fact that the finding by the Commissioner (Appeals) that a new firm was constituted to which the assets of the old dissolved firm were transferred was subsequently constituted was factually incorrect. In our opinion, a wrong of fact has vitiated the order of the Commissioner (Appeals). She has also not passed a speaking order as to how by transfer of the asset to the firm in which Shri Punjabi is a partner, it has reduced the tax liability of the assessee-firm. In such circumstances we are of the opinion that the matter should be restored to the file of the Commissioner (Appeals) who should record a correct finding of fact and also pass a speaking order on the applicability of Explanation 3 below Section 43 of the Income-tax Act, 1961 that the transfer of assets to the assessee-firm is with a view to reduce the tax liability. He should also consider as to whether the sale deed is not a genuine arrangement. We, therefore, set aside the order of the Commissioner (Appeals) and restore the issue to his file for a fresh determination in the light of the above observations. Both the parties will be given an opportunity before redetermining the issue.\n<\/p>\n
On the basis of the said observation the Commissioner (Appeals) went ahead to examine the issue. The Commissioner (Appeals) was of the view that since the retiring partners were paid a sum of Rs. 1,56,000 representing their 50 per cent share, to that extent the cost of the assets of the earlier firm had gone up. The learned Commissioner (Appeals) also considered the details of assets of the earlier firm which was the basis on which the dissolution was agreed to by the partners which break-up is already reproduced above. The Commissioner (Appeals) considered the issue that though Mr. Narain M. Punjabi was the partner in both the firms but in view of the fact he had paid off the other partners and brought in the assets to the new firm, the transaction is a genuine one resulting in acquisition of the assets at a higher value thereby the firm is entitled to depreciation at the value brought in by Shri Narain M. Punjabi.\n<\/p>\n
5.  Aggrieved by the finding of the Commissioner (Appeals) the department has come in appeal before us and the main stress before us was that Section 43 read with Explanation 3 clearly  demolishes the  claim  of the assessee that this is only a device with a view to reduce  the income-tax liability. On the other hand for the assessee reliance  was placed  on the orders of the Commissioner (Appeals) stating that the entire submissions of the assessee had been brought out by the Commissioner (Appeals).\n<\/p>\n
6.  We have heard the submissions of the parties and have very carefully considered the issue at length. First we shall deal with the issue of depreciation on the cost as claimed by the assessee. The cost according to the assessee has appreciated in view of the arrears  of lease money payable, liability   of  exhibitors   and   amount   due to  the partner, Mr. Narain M. Punjabi. It is not the claim of the assessee that the above amounts are encumbrances on the assets of the earlier firm. They may no  doubt be encumbrances on the business as such, like the sundry creditors who are unsecured creditors. Unless and until the liabilities are secured  on  the assets and the asset is taken  over  subject to the encumbrances on the asset, the take-over does not result in increase in the cost of the assets. The market value of the property so taken over on  dissolution could be more which might have led  Mr. Narain M. Punjabi to take over the liability as well, but this by itself does not necessarily lead to  the conclusion that the cost of the assets so taken over is to be enhanced to the extent of the liabilities taken over. As regards the dissolution of the firm and the subsequent revaluation of the assets for the purposes of adjustment of accounts between the partners is concerned it is purely an inter se arrangement between the partners and does not in any way increase or decrease the cost of the assets. Recognising this principle, in Section 47(ii) of the Act the Legislatures have provided that the distribution of assets amongst the partners as a consequence of dissolution of the firm would not be treated as a transfer. Therefore, the claim of the assessee that since the other partners were settled at a higher value than what was in their capital account before the revaluation of the assets resulted in increase in the cost in his hands is not an acceptable proposition and even on logic it is clearly an unacceptable proposition. The fallacy in the argument is also brought out by the fact that on dissolution there is no sale by some partners to another partner but only adjustment of each others interest in the firm’s assets amongst the partners. If it is to be treated as a sale which is not the case of the assessee, then in the hands of the earlier firm provisions of Section 41(2) of the Act would get attracted which provides for bringing into tax the amount of depreciation already allowed to the firm when an asset is sold. To this issue the argument of the assessee would be that there is no sale and, therefore, Section 41(2) would not get attracted. At this point of time the provisions of Section 43 regarding the actual cost becomes relevant. The provisions of Section 43 are brought out here :\n<\/p>\n
In Sections 28 to 41 and in this section, unless the context otherwise requires–\n<\/p>\n
(1) ‘actual cost’ means the actual cost of the assets to the assessee, reduced by that portion of the cost thereof, if any, as has be in met directly or indirectly by any other person or authority:\n<\/p>\n
 **                        **                       **<\/p>\n
Explanation 3 : Where, before the date of acquisition by the assessee, the assets were at any time used by any other person for the purposes of his business or profession and the Income-tax Officer is satisfied that the main purpose of the transfer of such assets, directly or indirectly to the assessee, was the reduction of a liability to income-tax (by claiming depreciation with reference to any enhanced cost), the actual cost to the assessee shall be such an amount as the Income-tax Officer may, with the previous approval of the Inspecting Assistant Commissioner, determine having regard to all the circumstances of the case.\n<\/p>\n
Reading of the section clearly brings out that actual cost means the actual cost of the asset to the assessee. We have already observed above that the claim of the assessee that the cost has enhanced is pulpably wrong. Even considering the Supreme Court decision in the case of Sunil Siddharthbhai v. CIT [1985] 156 ITR 509 recently concluded by their Lordships of the Supreme Court, we find that our view on the subject as regards the cost is on proper lines. Their Lordships had observed that the issue of the assets being valued by credit to the partner’s capital account when the asset is brought in by that partner. Their Lordships observed that:\n<\/p>\n
. . .The credit entry made in the partner’s capital account in the books of the partnership firm does not represent the true value of the consideration. It is a notional value only, intended to be taken into account at the time of determining the value of the partner’s share in the net partnership assets on the date of dissolution or on his retirement, a share which will depend upon deduction of the liabilities and prior charges existing on the date of dissolution or retirement….\n<\/p>\n
 **                        **                      **<\/p>\n
. . . When his personal assets merge into the capital of the partnership firm, a corresponding credit entry is made in the partner’s capital account in the books of the partnership firm, but that entry is made merely for the purpose of adjusting the rights of the partner inter se. When the partnership is dissovled or the partner retires it evidences no debt due by the firm to the partner . . . Having regard to the nature and quality of the consideration which the partner may be said to acquire on introducing his personal assets into the partnership firm as his contribution to its capital, it cannot be said that any income or gain arises or accrues to the assessee in the true commercial sense which a businessman would understand as real income or gain.\n<\/p>\n
7.  The above principle  as evolved by their Lordships of the Supreme Court clearly goes to establish that in a situation like the  one before us, i.e., dissolution of a firm and one of the partners taking the assets of the firm to himself and subsequently introducing it as his capital contribution to the firm does not result in the enhancement of the value of the assets as such and the actual cost of the asset is not at all affected by the method followed by an assessee. The conclusion is, therefore, obvious that the cost to the assessee on which depreciation has to be allowed  shall be the cost in the hands  of the previous owner,  namely, the firm New Tej Talkies less the depreciation as was already allowed to that firm. This actual cost shall not undergo any change under any circumstances unless and until the transaction is one of sale and as has been observed by their Lordships in the case of Malabar Fisheries Co. v. CIT [1979]  120 ITR 49 (SC) read with their Lordships’ view in the case of Sunil Siddharthbhai (supra), the only plausible conclusion is that the written  down value in the instant case has to be taken to be Rs. 76,931  which is the written down value after allowing of depreciation in the hands of the earlier firm New Tej Talkies  as it is not a sale by New Tej Talkies  to   the assessee-firm via Mr. Narain M. Punjabi.\n<\/p>\n
8.  In the result, the appeal of the department, therefore, succeeds resulting in quashing of the order of the Commissioner (Appeals) and restoring that of the ITO.<\/p>\n","protected":false},"excerpt":{"rendered":"
Income Tax Appellate Tribunal – Jaipur Income-Tax Officer vs Lalit Exhibitors on 30 October, 1986 Equivalent citations: 1987 20 ITD 239 JP Bench: H Ahluwalia, A Kalyanasundharam ORDER A. Kalyanasundharam, Accountant Member 1. This is an appeal by the revenue in which the only issue is the cost of the assets introduced in the firm […]<\/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":[1],"tags":[],"class_list":["post-97655","post","type-post","status-publish","format-standard","hentry","category-judgements"],"yoast_head":"\nIncome-Tax Officer vs Lalit Exhibitors on 30 October, 1986 - 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\/income-tax-officer-vs-lalit-exhibitors-on-30-october-1986\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Income-Tax Officer vs Lalit Exhibitors on 30 October, 1986 - 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