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Case lawHigh Court › CIT v V.S. Dempo & Co. Pvt. Ltd. (Bombay High Court, Full Bench) — section 172 is referable to section 44B, and where it applies there is no warrant for Chapter XVII or section 195
High CourtHelps taxpayerValidity unconfirmeds.172s.172(1)s.172(2)s.172(8)s.44Bs.195s.40(a)(i)s.194Cs.260A

CIT v V.S. Dempo & Co. Pvt. Ltd. (Bombay High Court, Full Bench) — section 172 is referable to section 44B, and where it applies there is no warrant for Chapter XVII or section 195

We are an Indian exporter. We paid demurrage to a foreign shipping company without deducting tax and the Assessing Officer has disallowed the whole payment under section 40(a)(i), saying section 172 is for non-residents and we are a resident. Does the payer have to be a non-resident before section 172 can be invoked?

We are an Indian exporter. We paid demurrage to a foreign shipping company without deducting tax and the Assessing Officer has disallowed the whole payment under section 40(a)(i), saying section 172 is for non-residents and we are a resident. Does the payer have to be a non-resident before section 172 can be invoked?

No. A Full Bench of the Bombay High Court answered the referred question and held that s.172 and s.44B are to be read together — s.44B enacting the special provisions for computing the profits and gains of a non-resident's shipping business and s.172 enacting the scheme for the levy and recovery of tax on the ship — and that where s.172 governs, there is no warrant for applying the provisions in Chapter XVII for collection and recovery of tax and its deduction at source under s.195. The Court overruled the view in CIT v. Orient (Goa) Private Limited to the extent contrary to that, and directed the appeals to be listed before an appropriate Division Bench.

Decided by the High Court (Full Bench of three Judges: S.C. Dharmadhikari, R.D. Dhanuka and B.P. Colabawalla JJ (judgment delivered by S.C. Dharmadhikari J); reserved on 27 November 2015) on 2016-02-05, reported as Income Tax Appeal No. 989 of 2015 and connected appeals, High Court of Judicature at Bombay, pronounced 5 February 2016 (file reference ITXA989.15.doc); no law-report citation was printed on the source read. It bears on section 172, section 172(1), section 172(2), section 172(8), section 44B, section 195, section 40(a)(i), section 194C, section 260A of the Income Tax Act 1961, in TDS Defaults, Presumptive Taxation & Audit, Deductions & Disallowances and How Tax Law Is Read matters.

Validity check could not be completed. Validity check could not be completed. I ran no search for any appeal against this Full Bench judgment or for later High Court or Supreme Court treatment of it, and I make no claim that none exists. What I can report is that the Supreme Court order of 5 September 2016 in Civil Appeal No. 4797/2008 between the same parties, which a title search surfaces, is a different case on s.50 and s.54E and is not an appeal from this judgment. Two features of the decision a reader should weigh for himself: it answers a reference and does not dispose of the appeals, and the Revenue was not represented at the hearing.

Why it matters

This is the decision a practitioner needs when the Assessing Officer's answer to Circular No. 723 is "but my assessee is a resident". That was the reasoning in Orient (Goa), where the Court had held that s.172 applies only to non-residents carrying on shipping business, that a resident Indian company therefore could not place reliance on it, and that s.195 accordingly applied with s.40(a)(i) consequences. The Full Bench was constituted on 9 October 2015 precisely because a Division Bench hearing Income Tax Appeal Nos. 989 and 991 of 2015 on 8 September 2015 could not agree with that view. Two things in the Full Bench's answer are worth carrying into practice. First, the structural point the brief for this area most needs and which is stated in the Court's own words: s.172 sits in Chapter XV, Liability in Special Cases, Profits of Non-residents, and "section 172 is referable to section 44B" — both open with a non-obstante clause, s.44B computing the profits and s.172 providing the machinery for levy and recovery on the voyage, with the sub-sections of each drawing demurrage and handling charges into the base. Second, the conclusion drawn from that: read together and harmoniously, the sub-sections of s.172 show how the tax is to be levied, computed, assessed and recovered, and there is therefore no warrant for applying Chapter XVII to the same income. The limits should be stated as squarely as the holding. The Court answered a reference; it did not dispose of the appeals, which it sent to a Division Bench. And the Revenue's counsel did not appear at the hearing, which the Court recorded and criticised — a point an opponent may raise and which you should be ready for.

Binding within that High Court's jurisdiction. Persuasive elsewhere.

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