08 October 2009
please any of you give me the supreme court decision about CIT v/s Mother india refrigeration industries pvt. Ltd. [1985] 155 ITR 711 (SC) circular no.5 of 2005, dt.15th july, 2005
Statutory Interpretation -- Construction -- Legal Fiction -- Not To Extend Beyond Legitimate Field
HEADNOTE :
statutory interpretation - construction - legal fiction - not to extend beyond legitimate filed.
Held
It is true that proviso (b) to s. 10(2)(Vi) creates a legal fiction and under that fiction, unabsorbed depreciation either with or without current years's depreciation is deemed to be the current year's depreciation but it is well settled, that the legal fictions are created only for some definite purpose and these must be limited to that purpose and should not be extended beyond that legitimate field. Clearly, the avowed purpose of the legal fiction created by the deeming provision contained in proviso (b) to s. 10(2)(Vi) is to make the unabsorbed carried forward depreciation partake of the same character as the current depreciation in the following year, so that it is available, unlike unabsorbed carried forward business loss, for being set off against other heads of income of that year. - Bengal immunity company limited vs. State of bihar [1955] 2 scr 603 followed.
Conclusion
Legal fiction cannot be extended beyond legitimate field.
Case law analysis
Bengal immunity company limited vs. State of bihar [1955] 2 scr 603 followed.
Counsel
B. B. Ahuja for the appellant. Harish salve for the applicant. S. T. Desai & b. B. Ahuja for the respondent. Harish salve for the interveners.
JUDGE(S) :
Ranganath Misra Sabyasachi Mukharji V D Tulzapurkar
TEXT :
COMMISSIONER OF INCOME-TAX, KANPUR v. MOTHER INDIA REFRIGERATION INDUSTRIES P LTD. (C A NOS 1570 AND 1571 OF 1973) HINDUSTAN VACUUM GLASS LTD. v. COMMISSIONER OF INCOME-TAX, DELHI (TAX REFERENCE CASE NO 15 OF 1983).
Civil Appeals Nos. 1570 and 1571 of 1973 and Tax Reference Case No. 15 of 1983, decided on August 14, 1985.
JUDGMENT
The judgment of the court was delivered by
TULZAPURKAR J. - In these appeals and the tax reference, the common question arising for determination relates to the priority between current depreciation and unabsorbed carried forward business lose, that is to say, which should be deducted first while computing the total income of an assessee for the concerned assessment year.
The facts giving rise to the above question in the civil appeals are these. The concerned assessment years are 1951-52 and 1952-53. At the end of assessment year 1950-51, there was an unabsorbed business loss of Rs. 67,534 and unabsorbed depreciation of Rs. 1,78,154. The assessee's income without taking into account the current depreciation was Rs. 50,624 in 1951-52 and Rs. 64,332 in 1952-53. The assessee contended before the ITO that before deducting the current depreciation from the above profits, the unabsorbed loss of the earlier year 1950-51 should be first set off. The ITO did not accept the contention and what he did was that from the profit Rs. 50,624 for 1951-52, the depreciation allowance for that year amounting to Rs. 58,140 was partially set off and the balance of the depreciation of Rs. 7,516 was ordered to be carried forward with the result that the total unabsorbed depreciation carried forward amounted to Rs. 1,85,670. It was further directed that the entire unabsorbed loss amounting to Rs. 67,534 should also be carried forward. Similarly, in 1952-53, the full depreciation allowance of that year amounting to Rs. 44,580 was set off against the income of Rs. 64,232; the net income of Rs. 19,652 (Rs. 64,232 minus Rs. 44,580) was utilised for setting off a part of the carried forward business loss of Rs. 67,534 leaving a balance of unabsorbed loss to the extent of Rs. 47,832. Both the unabsorbed amounts (Rs. 1,85,670 and Rs. 47,832) were directed to be carried forward. Aggrieved by the ITO's refusal to give preference in the matter of set off to the earlier carried forward business loss before deducting the current year's depreciation, the assessee preferred appeals for both the years and the AAC accepted the assessee's contention and directed that unabsorbed carried forward business loss should be set off first in each year before deducting the current year's depreciation. The Department preferred further appeals to the Appellate Tribunal and relying upon the decision of the Calcutta High Court in Aluminium Corporation of India v. CIT [1958] 33 ITR 367 (Cal), the Tribunal accepted the Department's contention and restored the ITO's decision. At the instance of the assessee, the following question was referred to the High Court for its opinion :
"Whether for the assessment years 1951-52 and 1952-53, the assessee was entitled to deduct the unabsorbed business loss at the end of the assessment year 1950-51, before setting off the depreciation allowance of Rs. 58,140 and Rs. 44,580,respectively, for these years ?"
After referring to the relevant provisions of the Income-tax Act, 1922, namely,ss. 10 and 24, particularly proviso (b) to s. 10(2)(vi) and s. 24(2), provision (b), the High Court answered the question in favour of the assessee. The Revenue has challenged the High Court's view in these appeals.
The facts in the tax reference are briefly these. For the assessment year 1969-70, the assessee company filed a return on July 18, 1969, disclosing a loss of Rs. 50,736; subsequently a revised return was filed on August 20, 1971,claiming a set-off of the carried forward loss of earlier years against the income of that year even before making any allowance for the current year's depreciation. The ITO held that the carried forward loss could not be given priority over the current year's depreciation in the matter of set off and completed the assessment determining the unabsorbed depreciation for the year at Rs. 40,255, brought forward development rebate at Rs. 8,020 and the carried forward past losses were allowed to be carried forward in full. In appeal, the AAC following the decision of the Allahabad High Court in the case of Mother India Refrigeration Industries (P) Ltd. [1971] 80 ITR 510 (which decision is the subject matter of civil appeals before us), accepted the assessee's contention that the carried forward losses have priority not only over the unabsorbed depreciation of the past years but also over the current year's depreciation in the matter of set-off. The Department preferred an appeal to the Appellate Tribunal and the Tribunal took the view that unabsorbed carried forward losses of the earlier years will have priority over unabsorbed depreciation of the earlier years but not over the current year's depreciation. In coming to this conclusion, the Tribunal placed certain construction on the relevant provisions of the 1961 Act, namely, ss. 32(2) and 72(2). In other words, it Prferred the views of the Calcutta High Court in Aluminium Corporation's case [1958] 33 ITR 367 (Cal) and of the Andhra Pradesh High Court in Addl. CIT v. Andhra Printers Ltd. [1979] 117 ITR 555 (AP), in so far as the competition for priority was between unabsorbed carried forward loss and current depreciation. At the instance of the assessee,in view of the conflict of decisions between the various High Courts, the Tribunal has referred the following question of law for this court's opinion under s. 257 of the Income-tax Act, 1961 :
"Whether, on the facts and in the circumstances of the case, the depreciation for the current year should be deducted before deducting the unabsorbed carried forward business losses having regard to the provisions of s. 72(2) read with s. 32(2) of the Income-tax Act, 1961 ?"
Since the answer to the question raised depends upon the proper construction to be placed on the relevant provisions of the 1922 Act as also of the 1961 Act, it will be necessary to set out the relevant provisions. Under the 1922 Act,s. 10(2)(vi) permits, while computing profits or gains of business, a deduction by way of depreciation allowance in respect of buildings, machinery, plant or furniture of a sum equivalent to such percentage on the written down value thereof as may be prescribed. Then comes proviso (b) to the aforesaid provision which is material. The relevant portion of proviso (b) (omitting unnecessary words) runs thus :
"(b) Where, in the assessment of the assessee full effect cannot be given to any such allowance in any year owing to there being no profits or gains chargeable for that year, or owing to the profits or gains chargeable being less than the allowance, then, subject to the provisions of clause (b) of the proviso to sub-s. (2) of s. 24, the allowance or part of the allowance to which effect has not been given, as the case may be, shall be added to the amount of the allowance for depreciation for the following year and deemed to be part of that allowance, or if there is no such allowance for that year be deemed to be allowance for that year, and so on for succeeding years;"
Section 24 provides for setting off of loss in computing aggregate income. Sub-section (1) thereof provides for setting off of loss of profits or gains under one head against profits or gains under any other head in the same year. Sub-section (2) thereof runs thus :
"(2) Where any assessee sustains a loss of profits or gains in any year...in any business,profession or vocation, and the loss cannot be wholly set off under sub-s. (1) so much of the loss as is not so set off or the whole loss where the assessee had no other head of income shall be carried forward to the following year, and
(i) ...
(ii) where the loss was sustained by him in any other business, profession or vocation (meaning other than speculative business), it shall be set off against the profits and gains, if any,of any business, profession or vocation carried on by him in that year : provided that the business, profession or vocation in which the loss was originally sustained continued to be carried on by him in that year;..."
Then comes proviso (b) to sub-s. (2) which is material and it runs thus :
"(b) where depreciation allowance is, under clause (b) of the proviso to clause (vi) of sub-s. (2) of s. 10, also to be carried forward, effect shall first be given to the provisions of this sub-section;"
Under the 1961 Act, the material provisions are to be found in s. 32(1) and (2) and s. 72(1) and (2) and it was not disputed that the material provisions in both the Acts are couched in substantially the same language. Two more things which are common under both the Acts need be noticed. Unabsorbed carried forward business loss can be set off only against business income of the following year or years while depreciation can be deducted from income under any other head ; further while the former can be carried forward for a limited number of years as specified in the enactment there is no time-limit prescribed for carrying forward unabsorbed depreciation.
Counsel for the Revenue urged that on a proper construction of the proviso (b) to s. 10(2)(vi) read with the proviso (b) to s. 24(2) of the 1922 Act (equivalent to s. 32(2) read with s. 72(2) of the 1961 Act), it is apparent that unabsorbed carried forward losses of the earlier years have been given priority over unabsorbed depreciation of the earlier years but not over the current year's depreciation for, under proviso (b) to s. 10(2)(vi), it is the carry forward (actual words used are "added to") of unabsorbed depreciation to the following year that is made subject to the proviso (b) to s. 24(2), that is to say, the preference given to the unabsorbed carried forward losses of the earlier years under proviso (b) to s. 24(2) is over the unabsorbed depreciation and not over the current depreciation. Counsel further urged that such a construction is in accord with the basic and well-recognised principle of commercial accountancy that in computing the profits and gains of business for a particular year, that year's depreciation (meaning current depreciation) is always to be treated as the first charge on such profits and gains and that is also the scheme of the Act. According to him, tax is payable on the total income of the concerned year, that such income includes profits and gains of a business, that the profits and gains must mean net profits and gains and net profits and gains cannot be ascertained without debiting the current year's depreciation to the profit and loss account of that year and it is in accordance with this principle of commercial accountancy that preference to unabsorbed carried forward losses has not been given over current depreciation but has been given over the unabsorbed depreciation of the earlier years in the matter of set off. In fact,counsel contended that having regard to well-settled principles of accountancy and the aforesaid provisions of the Act, there can be no competition between current year's depreciation and unabsorbed carried forward losses and the current depreciation must be deducted first before unabsorbed carried forward losses are set off. In support of his submissions, counsel relied upon four decisions : Aluminium Corporation of India Ltd. v. CIT [1958] 33 ITR 367 (Cal), CIT v. Gujarat State Warehousing Corporation [1976] 104 ITR 1 (Guj), Addl. CIT v. Andhra Printers Ltd. [1979] 117 ITR 555 (AP) and CIT v. Malwa Sugar Mills Co. Ltd. [1982] 134 ITR 56 (Cal). In all these decisions, the view taken is that current depreciation has to be deducted first before unabsorbed carried forward business losses are set off. He pointed out that the high court in deciding the question in favour of the assessee referred to a decision of this court in Jaipuria China Clay Mines (P.) Ltd. [1966] 59 ITR 555, and relied on certain observations made therein but the point that arose for decision in that case was entirely different and the observations cannot be divorced from the context of the point decided therein.
On the other hand, counsel for the assessees, in the appeals and the tax reference, strongly relied upon the legal fiction arising from the deeming provisions contained in proviso (b) to s. 10(2)(vi) of the 1922 Act and s. 32(2) of the 1961 Act as a result whereof the unabsorbed depreciation is not merely carried forward to the following previous year but is deemed to be the depreciation for that year and according to counsel,this entire aggregate depreciation is made subject to the proviso (b) to s. 24(2)(of the 1922 Act) or to s. 72(2)(of the 1961 Act). Counsel urged that this legal fiction must be given full effect without any reservation and, therefore, between the aggregate amount of depreciation and the unabsorbed carried forward losses, priority has to be given to the latter in the matter of set off. It was further urged that the Revenue cannot rely upon the principles of commercial accountancy, however well settled or well recognised these might be, in order to achieve a result contrary to what is warranted by the express provision of the statute including the legal fiction, if any, created therein; in other words, principles of commercial accountancy, if they are modified or deviated from by statute, cannot be allowed to prevail over statutory provisions. It was also urged that the construction of the relevant provisions suggested by the assessee and which has been accepted by the High Court has some advantages and, therefore, should be preferred to the construction suggested by the Revenue.
Having regard to the aforesaid rival contentions, it will be clear that the real issue that arises for our consideration in this case is whether, on a proper construction of the relevant provisions of the concerned enactment, unabsorbed carried forward losses should have preference over current depreciation in the matter of set off or is the position vice versa while computing the total income of an assessee in the concerned assessment year ? And the answer to this question depends on what is the true scope and purpose of the legal fiction created under proviso (b) to s. 10(2)(vi) of the 1922 Act or under s. 32(2) of the 1961 Act.
At the outset, it may be stated that a close scrutiny of the relevant provisions of the 1922 Act as also the 1961 Act clearly shows that the computation of income under the head "Profits and gains of business" of any particular assessment year is required to be done after making certain allowances specified in sub-s. (2) of s. 10 of the 1922 Act and after allowing certain deductions in accordance with the provisions contained in ss. 30 to 43A of the 1961 Act; in other words, it is the net profits and gains after the specified deductions are made that are subjected to tax; one of such deductions pertains to depreciation allowance at the prescribed rate of percentage of the written down value of the business asset; and this is provided in s. 10(2)(vi) of the 1922 Act and in s. 32(1) of the 1961 Act. Up to this stage of computation, no question of either carry forward of unabsorbed depreciation of the earlier years or carry forward of unabsorbed business losses of earlier years arises. In other words, the normal accountancy principle has to be applied in arriving at the net income from business for that year by debiting the current year's depreciation. The question is whether any deviation from this normal rule of accountancy is contemplated by proviso (b) to s. 10(2)(vi) read with proviso (b) to s. 24(2) of the 1922 Act or by s. 32(2) read with s. 72(2) of the 1961 Act, and it is here that the aspect of proper construction of these provisions arises. Dealing with the provisions of the 1922 Act first, it will be clear that proviso (b) to s. 10(2)(vi) is in two parts and provides for two things; its second part provides for clubbing the said carry forward of unabsorbed depreciation and its second part provides for clubbing the said carried forward depreciation with the current year's depreciation and deeming the aggregate to be the current year's depreciation. However, carrying forward of the unabsorbed depreciation and the deeming provision in proviso (b) are not absolute but are subject to the proviso (b) to s. 24(2). Had proviso (b) to s. 24(2) not been enacted by the legislature, the result would have been that the aggregate depreciation would have been deducted first out of the profits and gains in preference to unabsorbed business losses which might have been carried forward under s. 24(2) but as such losses can be carried forward only for limited number of years, the assessee would in certain circumstances have in his books losses which he might not be able to set off even within the time-limit during which the set off is permitted. In order to prevent such a situation, the Legislature enacted the proviso (b) to s. 24(2). And proviso (b) to s. 24(2) expressly states "where depreciation allowance is, under cl. (b) of the proviso to cl. (vi) of sub-s. (2) of s. 10, also to be carried forward, effect shall first be given to the provisions of this sub-section". In other words, it clearly provides that in the matter of set off, the unabsorbed business losses of the earlier years will have preference over unabsorbed depreciation that is required to be carried forward under proviso (b) to s. 10(2)(vi) and no preference over the current depreciation is intended.
It is true that proviso (b) to s. 10(2)(vi) creates a legal fiction and under that fiction, unabsorbed depreciation either with or without current year's depreciation is deemed to be the current year's depreciation but it is well settled, as has been observed by this court in Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603, 606; 6 STC 446, that the legal fictions are created only for some definite purpose and these must be limited to that purpose and should not be extended beyond that legitimate field. Clearly, the avowed purpose of the legal fiction created by the deeming provision contained in provision (b) to s. 10(2)(vi) is to make the unabsorbed carried forward depreciation partake of the same character as the current depreciation in the following year, so that it is available, unlike unabsorbed carried forward business loss, for being set off against other heads of income of that year. That this is so becomes clear from this court's observations in Jaipuria China Clay Mines (P.) Ltd.'s case [1966] 59 ITR 555, appearing at p. 561 of the report, which runs thus :
"The unabsorbed depreciation allowance is carried forward under provision (b) to s. 10(2)(vi) and the method of carrying it forward is to add it to the amount of the allowance or depreciation in the following year and deeming it to be part that allowance; the effect of deeming it to be part of that allowance is that it falls in the following year within cl. (vi) and has to be deducted as allowance."
In CIT v. Ravi Industries [1963] 49 ITR 145 (Bom), the same position has been clarified by the Bombay High Court. The court has observed that the unabsorbed depreciation does not lose its character and attributes when it is carried forward to the following year; such unabsorbed depreciation of the earlier year, which is carried forward to the current year and which is deemed to be of the current year under provision (b) of s. 10(2)(vi) can be set off, unlike other business losses, against income under other heads. Such being the purpose for which the legal fiction is created, it is difficult to extend the same beyond its legitimate field and will have to be confined to that purpose. It is, therefore, not possible to accept the contention of counsel for the assessees that because of the legal fiction, the unabsorbed carried forward losses should be given preference not merely over the unabsorbed carried forward depreciation but also over the current year's depreciation. There is thus no modification of, nor deviation from, the basic and well recognised principle of commercial accountancy by the statute as is contented by counsel for the assessees.
Since the provisions of the 1961 Act are in pari materia with the corresponding provisions under the 1922 Act, the same conclusion must follow under the 1961 Act, namely, that the current depreciation must be deducted first before deducting the unabsorbed carried forward business losses of the earlier years in giving set off while computing the total income of any particular year.
Having regard to the above discussion, it seems to us clear that unabsorbed carried forward losses cannot be given preference over current depreciation in the matter of set off in computing an assessee's income for any particular assessment year and, as such, the question has been correctly decided in Aluminium Corporation's case [1958] 33 ITR 367 and Malwa Sugar Mills case [1982] 134 ITR 56 by the Calcutta High Court, in Gujarat State Warehousing Corporation's case [1976] 104 ITR 1 by the Gujarat High Court and in Andhra Printers' case [1979] 117 ITR 555 by the Andhra Pradesh High Court. In the impugned judgment in the Civil Appeals, the High Court has relied on some observations of this court in Jaipuria China Clay Mines' case [1966] 59 ITR 555, but that case dealt with a different point altogether and, as such, the observations made in the context of the points that arose for decision there would be of no avail. The High Court's decision in the Civil Appeals is, therefore, set aside and that of the Tribunal is restored while in Tax Reference, the question referred to this court is answered against the assessee to the effect that the depreciation for the current year must first be deducted before deducting the unabsorbed carry forward business loss. The assessees will pay the costs of the appeals and tax reference to the Department.
BACKWARD REFERENCE :
[Over-rules]
1970-(IT2)-GJX -0294 -ALL
[Referred]
1965-(IT2)-GJX -0298 -SC Commissioner Of Income-tax, Calcutta V. Jaipuria China Clay Mines (P). Ltd. 1981-(IT2)-GJX -0424 -CAL Commissioner Of Income-tax, West Bengal-iv V. Malwa Sugar Mills Co. Ltd. 1976-(IT2)-GJX -0570 -AP Additional Commissioner Of Income-tax, A.P. V. Andhra Printers Ltd. 1975-(IT2)-GJX -0515 -GUJ Commissioner Of Income-tax, Gujarat I V. Gujarat State Warehousing Corporation. 1957-(IT2)-GJX -0135 -CAL Aluminium Corporation Of India Ltd. V. Commissioner Of Income-tax, West Bengal. 1962-(IT2)-GJX -0337 -BOM Commissioner Of Income-tax, Bombay City I V. Ravi Industries Ltd.
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