Friday, 25 September 2020

Pre-conditions for invoking Section 263

 

Section 263 of the Act confers the power upon the Principal Commissioner or Commissioner to call for and examine the records of a proceeding under the Act and revise any order if he considers the same to be erroneous and prejudicial to the interests of the revenue. 

Analysis of the provision

Sub-Section (1) to Section 263 starts with the words “the Principal Commissioner or Commissioner may call for any record and examine the record of any proceeding”. There are 3 essential ingredients of this part.

Firstly, that “the Principal Commissioner or Commissioner may call for”. Therefore it is the absolute discretion of the Principal Commissioner or Commissioner to revise an order passed by the Assessing Officer. He need not take the permission of any authority/court for exercising his powers. The condition precedent is that he has to apply his own mind and come to a definite conclusion, which has to be an independent act and not act on the directions of the CBDT or any other authority. – [See Sirpur Paper Mill Ltd. v CWT (77 ITR 6) (SC) and CIT, Shimla v. Green world Corporation (2009) 314 ITR 81 : 7 SCC 69 (SC)]

Secondly, “record” has been given a wide connotation to mean not only the record before the Assessing Officer during scrutiny proceedings, but also any such material/information coming into the possession of the CIT even after the passing of the Assessing Officer’s order, if such record/information conclusively proves the Assessing Officer’s order is erroneous in so far as prejudicial to the interest of the revenue.

Thirdly, he can exercise such discretion in relation to “any order” passed by the Assessing Officer. Such order has been construed as not necessarily an order passed under section 143(3). Example an order rejecting the registration of a firm or; dropping the assessment proceedings even though a return has not been filed. Once an order passed by the Assessing Officer has attained finality meaning thereby it affects the rights of an assessee, the Principal Commissioner or Commissioner has the authority to revise any such order.

Requirement for assuming revisional jurisdiction under section 263

The Principal Commissioner or Commissioner can exercise power of revision under section 263 if the following factors are present :

(1)    there are any proceedings under the Act,

(2)    the assessing officer has passed an order in such proceedings, and

(3)    the Principal Commissioner or Commissioner is of the opinion that such order is erroneous and

         prejudicial to the interest of the revenue.

 

There must exist an written order, which is sought to be revised by the Commissioner.

 

[1]  There are any proceedings under the Act

The Principal Commissioner or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the  Assessing Officer is erroneous in so far as it is prejudicial to the interests of the revenue, he, may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including an order enhancing or modifying the assessment, or cancelling the assessment and directing a fresh assessment. 

 

Any issue, which Assessing Officer has not considered in the assessment under section 143 (3) r.w.s. 147, can be brought to life by Commissioner in exercise of his powers under section 263. – [Spencer & Co. Ltd. v. ACIT (2012) 137 ITD 141 (ITAT Chennai)]

[2]    The assessing officer has passed an order in such proceedings

Section 263 is not limited to exercising revisional powers qua order of assessment only; it would take within its sweep even orders wherein either proceedings are dropped or proceedings are filed

Gujarat High Court in case of New Jagat Textile Mills (P) Ltd. v. CIT, held as under:

(a) Section 263 of the Income-tax Act, 1961, empowers the Commissioner to take up for consideration 'any order passed' in any proceedings under the Act. In these circumstances, it is not possible to read the provisions as being limited to exercising revisional powers qua order of assessment only. It would take within its sweep even the orders wherein either the proceedings are dropped or the proceedings are filed.

 

(b) Therefore, once the twin conditions for exercise of jurisdiction under section 263 of the Act were shown to be fulfilled, the Commissioner was perfectly justified in taking action under the said provisions and exercising his revisional powers." – [New Jagat Textile Mills (P) Ltd. v. CIT (2006) 282 ITR 399 (Guj)]

 

Words 'any order’ under section 154 vs. 'the order’ under section 263

The words 'any order' in section 154(1)(a) would mean even the reassessment order under section 147. It cannot be stated that both the expressions, 'any order' and 'the order', as occur in sections 154 and 263 respectively, would have the same meaning. The word 'the' clearly denotes the specific order, while the word 'any' would mean any order passed by the Income-tax Authority. – [Rastriya Ispat Nigam Ltd. v. ACIT (2015) 377 ITR 420 (AP)]

The order passed by the authority, which is subordinate to the Commissioner, to give effect to the orders of the Tribunal is covered under the phrase “any order”. Thus, invoking of power of revision under Section 263 by the Commissioner is within the permissible limits of the law. – [Pentamedia Graphics Ltd. v. ACIT (2012) 17 ITR 302 (ITAT Chennai)]

The word 'order' mentioned in section 263 which can be the subject-matter of revision by the Commissioner would mean an order determining the rights and liabilities of the assessee under the Act. – [Smt. Bhartiben M. Kelawala v. CIT (2011) 128 ITD 4 (ITAT Ahmedabad)]

 

 

There cannot be revision of a non-existing order and where there is no order either for levy or waiver of interest under section 158BFA(I) or section 234A, 234B or 234C of Act in existence, Commissioner can have no jurisdiction to invoke provisions of section 263 for directing Assessing Officer to charge interest under section 158BFA(1) – [Anand Kumar Agarwal (HUF) v. ACIT (2005) 92 TTJ 81 (ITAT Agra)]

 

[3]   Provisions of section 263 can be invoked only when the twin conditions are satisfied i.e. order should be both erroneous and prejudicial to the interest of the Revenue

It is a well settled law that to invoke the provisions of section 263 both the conditions that the order must be erroneous and prejudicial to the interest of Revenue must be satisfied.

Provisions of section 263 reads –

“(1) The Principal Commissioner or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer is erroneous in so far as it is prejudicial to the interests of the revenue.

 

Twin conditions

The Commissioner gets power of revision under Section 263 where the assessment order is erroneous and prejudicial to the interest of revenue. The twin conditions are required to be satisfied simultaneously. – [S. Murugan v. ITO (2012) 135 ITD 527 (ITAT Chennai), J. K. Construction Co. v. ITO (2007) 162 Taxman 46 (ITAT Jodhpur)]

 

It was held that the Commissioner would assume jurisdiction under section 263 only when both the conditions, namely, the order passed by the assessing officer was erroneous and the same was prejudicial to the interest of the revenue were fulfilled and if the order was not prejudicial, the powers under section 263 could not be invoked. – [Surender Kumar Madan, Prop. Diamond Service Station v. ITO (2004) 179 Taxation 19 (ITAT Jabalpur)]

 

Commissioner required to decide the issue before determining the assessment order as erroneous and unsustainable in law – Order of Commissioner set aside 

Commissioner invoked revisionary jurisdiction under Section 263 of the Act setting aside the assessment and directed Assessing Officer to make a fresh assessment as he did not make an enquiry about the AIR information received regarding cash deposits made in the bank account of the assessee. Tribunal found that Commissioner had not concluded on the issue of inadequacy of cash in hand but required the Assessing Officer to do so. Tribunal held that Commissioner required to decide the aspect one way or the other before he could determine that the assessment order was erroneous. The initiation of proceedings under Section 263 of the Act were inconsistent with the requirement of Section 263(1) of the Act and therefore set aside by the Tribunal. (Related Assessment year : 2009-10) – [Adishwar K. Jain v. CIT (2019) 201 TTJ 77 : 181 DTR 29 : 52 CCH 606 (ITAT Mumbai)]

Conditions precedent - Where order under section 263 passed by CIT suffers from one of twin conditions, that order was prejudicial but not erroneous, the same could not give CIT power to invoke jurisdiction under section 263 as order of Assessing Officer must be prejudicial as well as erroneous both

Assessment of assessee was completed under section 143(3) where under total income of assessee was determined. CIT on examining relevant record opined that assessment made by Assessing Officer was erroneous and prejudicial to the interests of Revenue. CIT felt that Assessing Officer did not scrutinize reasons for reduction of assessee's income which got down by 50 per cent, compared to immediately preceding assessment year and did not examine arrangement of leasing out of godowns to two trusts. Tribunal held that CIT failed to bring out specifically any material into record disclosing any error in assessment order of Assessing Officer prejudicial to interests of revenue. Held: While exercising jurisdiction suo motu under section 263 CIT had to be satisfied with two conditions, namely, (i) that order of Assessing Officer sought to be revised was (i) erroneous; and (ii) it was also prejudicial to the interest of revenue. Foremost requirement that order must be erroneous for invoking revisional jurisdiction under section 263 by CIT, had not been satisfied in the instant case. Once order was not found erroneous, CIT was denuded of his power to invoke section 263 to revise assessment order. – [CIT v. V. Dhana Reddy & Co. (2018) 407 ITR 96 (AP)]

 

The ITAT in the case of Khatiza S. Oomerbhoy v. ITO, analysed in details various authoritative pronouncements including the decision of the hon'ble Supreme Court in the case of Malabar Industries Co. Ltd. v. CIT (2000) 243 ITR 83 (SC) and propounded the following broader tests :

(i)      The Commissioner of Income-tax must record satisfaction that the order of the Assessing Officer is erroneous and prejudicial to the interest of the Revenue. Both conditions must be fulfilled.

(ii)     Section 263 cannot be invoked to correct each and every type of mistake or error committed by the Assessing Officer and it was only when an order is erroneous that the section will be attracted.

(iii)   An incorrect assumption of facts or an incorrect application of law will suffice the requirement of order being erroneous.

(iv)    If the order is passed without application of mind, such order will fall under the category of erroneous order.

(v)     Every loss of revenue cannot be treated as prejudicial to the interests of the Revenue and if the Assessing Officer has adopted one of the courses permissible under law or where two views are possible and the Assessing Officer has taken one view with which the Commissioner of Income-tax does not agree. It cannot be treated as an erroneous order, unless the view taken by the Assessing Officer is unsustainable under law.

(vi)    If while making the assessment, the Assessing Officer examines the accounts, makes enquiries, applies his mind to the facts and circumstances of the case and determine the income, the Commissioner of Income-tax, while exercising his power under section 263 is not permitted to substitute his estimate of income in place of the income estimated by the Assessing Officer.

(vii)  The Assessing Officer exercises quasi judicial power vested in his and if he exercises such power in accordance with law and arrive at a conclusion, such conclusion cannot be termed to be erroneous simply because the Commissioner of Income-tax does not fee stratified with the conclusion.

(viii) The Commissioner of Income-tax, before exercising his jurisdiction under section 263 must have material on record to arrive at a satisfaction.

(ix)    If the Assessing Officer has made enquiries during the course of assessment proceedings on the relevant issues and the assessee has given detailed explanation by a letter in writing and the Assessing Officer allows the claim on being satisfied with the explanation of the assessee, the decision of the Assessing Officer cannot be held to be erroneous simply because in his order he does not make an elaborate discussion in that regard. – [Khatiza S. Oomerbhoy v. ITO (2006) 100 ITD 173 (ITAT Mumbai)]

 

Section 263 CIT must show that view taken by Assessing Officer is wholly unsustainable in law

Revisional Commissioner is expected show that the view taken by the Assessing Officer is wholly unsustainable in law before embarking upon exercise of revisionary powers. The revisional powers cannot be exercised for directing a fuller inquiry to merely find out if the earlier view taken is erroneous particularly when a view was already taken after inquiry.

 

If such course of action as interpreted by the Revisional Commissioner in the light of the Explanation 2 is permitted, Revisional Commissioner can possibly find fault with each and every assessment order without himself making any inquiry or verification and without establishing that assessment order is not sustainable in law.

This would inevitably mean that every order of the lower authority would thus become susceptible to Section 263 of the Act and, in turn, will cause serious unintended hardship to the tax payer concerned for no fault on his part. Apparently, this is not intended by the Explanation.

Howsoever wide the scope of Explanation 2(a) may be, its limits are implicit in it. It is only in a very gross case of inadequacy in inquiry or where inquiry is per se mandated on the basis of record available before the Assessing Officer and such inquiry was not conducted, the revisional power so conferred can be exercised to invalidate the action of Assessing Officer. The Assessing Officer in the present case has not accepted the submissions of the assessee on various issues summarily but has shown appetite for inquiry and verifications.

The Assessing Officer has passed the order in great detail after making several allowances and disallowances on the issues involved impliedly after due application of mind. Therefore, the Explanation 2 to Section 263 of the Act do not, in our view, thwart the assessment process in the facts and the context of the case. Consequently, we find that the foundation for exercise of revisional jurisdiction is sorely missing in the present case.

Resultantly, the order of the PCIT passed under section 263 of the Act is set aside and cancelled and the order of the Assessing Officer under 143(3) is restored. (Related Assessment Year : 2014-15) - [Torrent Pharmaceuticals Ltd v. DCIT - Date of Judgement : 08.08.2018 (ITAT Ahmedabad)]

 

Before taking any action under section 263, Commissioner must record his satisfaction; issuance of notice on basis of proposal made by ITO is void ab-initio

It was held that The CIT had not applied his mind but the matter was referred by the Assessing Officer for initiating the proceeding under section 263 of the Act.  It is noticed that the notice under section 263 of the Act was issued only on receipt of the proposal under section 263 of the Act from the ITO. and the assessee explained, vide written submission which has been reproduced. It is well-settled that the learned CIT while exercising the revisionary powers under section 263 of the Act may call for and examine the records of any proceedings and thereafter if he considers that any order passed therein is erroneous insofar as it is prejudicial to the interest of the Revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify. Therefore, before taking any action, learned CIT himself shall apply his mind after examining the record of any proceedings and his satisfaction is must. However, the satisfaction was of the Assessing Officer who proposed action under section 263 of the Act, but not of the learned CIT. Therefore, issuance of notice under section 263 of the Act on the basis of the proposal made by the ITO was void ab initio; therefore, the matter was set aside. (Related Assessment year 2008 09) – [Dharmendra Kumar Bansal v. CIT (2014) 161 TTJ 801 : (2015) 152 ITD 406 : 48 taxmann.com 53 (ITAT Jaipur)]

 

Revision of orders prejudicial to revenue – Restricted to directions given – Assessing Officer cannot go beyond the direction

Commissioner exercised its revisional jurisdiction and directed Assessing Officer to determine income from one of assessee’s business. Held, since revision order was confined to one of the businesses of the assessee and bereft of any discussion regarding the other business, the Assessing Officer was not justified in conducting enquires about such other business. On writ the court held that Assessing Officer annot go beyond the direction. (Related Assessment year : 2006-07) – [Shobha Govil (Smt.) v. Addl. CIT (2013) 354 ITR 668 : 218 Taxman 30 (Mag.)(All)]

 

Commissioner cannot simply remand the matter back to the Assessing Officer

The CIT cannot remand the matter to the Assessing Officer for further enquiries or to decide whether the findings recorded are erroneous without a finding that the order is erroneous and how that is so. A mere remand to the Assessing Officer implies that the CIT has not decided whether the order is erroneous but has directed the Assessing Officer to decide the aspect which is not permissible. – [ITO v. DG Housing Projects (2012) 343 ITR 329 (Del)]

 

In absence of any finding that there is loss of revenue, interference under section 263 is not justified

The finding of the Commissioner that the deductions were required to be given on account of the impurities and change of fashion, it is clear that even he did not regard the market rate as one that was required to be adopted. He has not found that the rate actually adopted is less than the one that should have been adopted. In the absence of any finding that there is loss of revenue, interference under Section 263 of the Act was not justified. – [CIT v. G. R. Thangamaligai (2003) 259 ITR 129 : 185 CTR 560 (Mad)]

 

Order for which revision is taken up should be in existence and served

An order passed by the Assessing Officer must be in existence. The Commissioner is not empowered under section 263 to direct the Assessing Officer to pass an order. – [P.P. Dinwala v. CIT (1995) 78 Taxman 421 (Cal.)]

 Order under section 263 should be speaking order

The assessee, M/s. Kashi Nath & Co., is a partnership firm. The firm was doing sarafa and pawning business. For the assessment year 1975-76, the Income-tax Officer determined its income at Rs. 77,599, There was no appeal to the Appellate Assistant Commissioner but the Commissioner of Income-tax in exercise of his power under Section 263 of the Income-tax Act set aside the assessment order and directed the . Income-tax Officer to redo the assessment. But the appeal against the said order of the Commissioner has been allowed by the Tribunal. The Tribunal has observed that the Commissioner has not given his reasons for his conclusion that the order of assessment was prejudicial to the interests of the Revenue. In our opinion, the conclusion of the Tribunal is unassailable.

 

It will be seen from the above order that the Commissioner did not examine the various cash credits said to be appearing in the names of different ladies which were said to have escaped the attention of the Income-tax Officer. He only complained of the order of the Income-tax Officer for not examining the details of the credits appearing in various names. What those details required to be examined were have not been set out. There is thus absolutely no reason in support of the conclusion of the Commissioner that the assessment order was erroneous and prejudicial to the interests of the Revenue.

 

The power of the Commissioner under Section 263 is quasi-judicial in character. He must give reasons in support of his conclusion that the assessment order is erroneous in so far as it is prejudicial to the interests of the Revenue. If he does not give reasons, the order would be vitiated. This was the view taken by this court in the case of J. P. Srivastava & Sons Ltd. v. CIT (1978) 111 ITR 326 (All) and CIT v. Sunder Lal (1974) 96 ITR 310 (All). In the instant case, since the Commissioner has not applied his mind to the relevant material on record and has not given reasons for his conclusions that the assessment order was prejudicial to the interest of the Revenue, the Tribunal was justified in reversing that order. (Related Assessment year : 1975-76) – [CIT v. Kashi Nath & Co. (1988) 170 ITR 28 (1987) 64 CTR 177 : 33 TAXMAN 577 (All)]

Order could not be said to exist unless communicated to the party

An order passed by the Assessing Officer is not effective till it is served on the assessee. Therefore, where the assessment order was passed but was not served it could not be made the subject of proceedings under section 263. – [Smt. Jijeebai Shinde v. Commissioner of Gift-Tax (1986) 157 ITR 122 (MP)]

 

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