Smt. Kubra Begum, Hyderabad vs Assessee

S.No I.T.A. No. Asst. Year Appellant Respondent 1. 666/HYD/14 Sri Mohammed Farooq, HYDERABAD [PAN: BQRPM7083B] Income Tax 2. 667/HYD/14 Smt. Bilquees Begum, Officer, HYDERABAD 2004-05 [PAN: BHKPB3137R] Ward-8(1), 3. 668/HYD/14 Sri Shaik Mahaboob, HYDERABAD HYDERABAD [PAN: DUMPS8418F] 4. 669/HYD/14 Smt. Kubra Begum, HYDERABAD [PAN: BHPPB9721G]

For Assessee : Shri S.Rama Rao, AR For Revenue : Shri Rajat Mitra, DR

S.No I.T.A. No. Asst. Year Appellant Respondent 1. 718/HYD/14 Mohammed Naseer, HYDERABAD Income Tax [PAN: AOYPN7033A] 2. 719/HYB/14 Mohammed Qaiser, Officer, 2004-05 HYDERABAD [PAN: CCEPK6028G] Ward-8(1), 3. 720/HYB/14 Mohammed Sabir, HYDERABAD HYDERABAD [PAN: DVHPS4560L]

For Assessee : Shri A.V. Raghuram, AR For Revenue : Shri Rajat Mitra, DR

Date of Hearing : 20-01-2015 Date of Pronouncement : 20-03-2015 ITA Nos. 666, 667, 668 & 669 /Hyd/2014 :- 2 -: 718, 719 & 720/Hyd/2014

ORDER

PER BENCH :

These are seven appeals by respective assessees against separate but common orders of the Commissioner of Income Tax(Appeals), Vijayawada having concurrent jurisdiction over Hyderabad vide order dated 31-01-2014. Since common issues are involved, these are heard together and decided by this common order.

2. We have heard the Ld.Counsels and Ld.DR and perused the Paper Books placed on record by the respective parties.

3. Briefly stated, assessees herein along with four others are co- owners of a property bearing Nos.8-3-483, 486 to 502 along with open land measuring 4702.52 Sq. Yds., (excluding the property having bearing No.8-3-483 comprising of 250 sq. Yds.), at Yellareddiguda, Hyderabad. Consequent to the information that these assessees have entered into a development agreement with M/s. Sun Mark Builders on 04-11-2003 for development of property for construction of residential flats sharing the built up area in the ratio of 39:61, assessing Officer initiated proceedings u/s.147 of the Income Tax Act (Act) in order to consider the capital gains arising to the assessees. Assessing Officer was of the opinion that assessees have received refundable security deposit which was not repaid, also received further amounts from the said developer as confirmed by them and further assessees have given possession of the property for development, therefore, capital gains arise on the day of agreement i.e., 04-11-2003 relevant to the impugned assessment year.

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4. In the course of assessment proceedings after issuance of notices u/s.148 dt.29-03-2011, assessees were asked to file returns of income again vide letter dt.05-10-2011 as there were no compliances, summons u/s.131 of the Act were issued and assessees have promised to file returns after obtaining the relevant PAN numbers. The returns were filed by four persons Sri Mohammed Farooq, Smt. Bilquees Begum, Sri Shaik Mahaboob and Smt. Kubra Begum, whereas returns have not been filed by the other three assessees Mohammed Naseer, Mohammed Qaiser and Mohammed Sabir. Assessing Officer completed the assessments u/s.144 of the Act and brought to tax capital gains at Rs.75,90,290/- in each case. In arriving at the above amount, Assessing Officer took the 1/11th portion of the security deposit received to an extent of Rs.11,00,165/- each and also considered the value of constructed area of flats to be received in lieu of area given for development and arrived at the value, based on the SRO, Valuation multiplied by the area totally received by the group (41,226 sq. Ft., X 1700). Sale consideration in each hand was arrived at Rs.63,71,290/-. The cost of acquisition was arrived at Rs.60/- per sq. Yd, on the basis of values obtained from SRO, Secunderabad and since assessees have not informed any other details, took the indexed cost at Rs.1,18,835/-, thereby, arriving at the capital gains as mentioned above.

5. Before the Ld.CIT(A), it was contended that assessees have entered into agreements and cancelled in earlier period also and therefore till the final handing over of the developed area, there is no capital gains arising to the assessees. In addition to the year of taxability of capital gains, assessees also brought to the notice of CIT(A) the various litigations, the permission granted by municipality subsequently in year 2006 and actual handing over in 2011. While contending that capital gains does not arise in the impugned assessment year, as an alternate contention, it was also contended that Assessing Officer has taken both the security ITA Nos. 666, 667, 668 & 669 /Hyd/2014 :- 4 -: 718, 719 & 720/Hyd/2014

deposit as well as so called sale value rather than cost of construction of the building by the builder. It was further submitted that cost of acquisition also includes the residential buildings available on the plot and further cost of vacating the tenants, litigation expenses charged by the builder to the owners. Assessee submitted before the CIT(A), that the cost of expenditure as charged by the builder, which they requested for allowing the same while computing the capital gain. In addition to the above, assessees also contended that they are eligible for deduction u/s.54 / 54F as they have obtained residential flats in lieu of the residential building parted with. Assessees filed detailed submissions before the Ld.CIT(A) including reliance on various case laws, which was extracted by the Ld.CIT(A) in the order.

6. Ld.CIT(A) however, did not agree with assessee's contentions. On the issue of year of taxability, Ld.CIT(A) noticed that assessee has handed over possession and also received deposits and further surrender of tenancy letters indicate that tenants have vacated before 14th March, 2003. Relying the above facts and also relying on the decision of the Hon'ble Bombay High Court in the case of Chaturbhuj Dwarkadas Kapadia Vs. CIT [260 ITR 491] and analysing the provisions of Section 2(47)(v) of the Act, confirmed the action of the Assessing Officer by holding that Assessing Officer is justified in bringing to tax the capital gain during the year on entering the development agreement. With reference to the cost of construction, CIT(A) did not accept the evidence submitted by assessee and as Assessing Officer requested the details from SRO, office for the fair market value, she confirmed the adoption of cost of construction. However, there is no finding on the issue of adoption of security deposit as well as cost of construction by the Assessing Officer, as sale consideration. Like-wise, there is also no adjudication on the issue raised by assessee with reference to cost of acquisition also. On the issue of claim of deduction u/s.54/54F, ITA Nos. 666, 667, 668 & 669 /Hyd/2014 :- 5 -: 718, 719 & 720/Hyd/2014

Ld.CIT(A) was of the opinion that the claim was not made in return hence, not allowable. Further claim of deduction u/s.54F can not be allowed as the capital gain has arisen on transfer of capital asset being used for the residential purposes by assessee, therefore, provisions of Section 54F are not applicable. Ld CIT(A) held that the facts of the cases relied upon are distinguishable, without specifying the distinguishing factors. In the result, assessee's appeals were dismissed by the Ld.CIT(A).

7. In all the appeals, the common issue contested by assessees is with reference to:

a. Year of taxability;

b. Sale consideration to be adopted;

c. Cost of acquisition to be considered;

d. Claim of deduction u/s.54 or 54F

8. In addition to the above four common issues, the three assessees who have not filed returns before the Assessing Officer also raised issue of jurisdiction in passing the order u/s.144 ex-parte. These issues are considered as under.

A: Year of Taxability:

9. With reference to the year of taxability of capital gains, there is no dispute with reference to the fact that assessees hereinabove entered into an agreement for development on 04-11-2003. It is also agreed upon by both the parties that construction shall be completed within 42 months from the date of agreement. Assessing Officer while completing the assessment has taken into consideration the fact of receipt of deposit and also handing over the possession, while invoking the definition of transfer u/s.2(47). He relied upon the following decisions:

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i. Chaturbhuj Dwarkadas Kapadia Vs. CIT [260 ITR 491] ii. Jasbir Singh ..in RE AAR (2007) 294 ITR 196 (AAR); iii. Dr. T.Atchuta Rao Vs. ACIT [106 ITD 388 (Hyd)]

10. In view of the facts and the law relied upon by the Assessing Officer, he held that the transaction satisfies the conditions of Section 53A of Transfer of Property Act and therefore, transaction is covered under 2(47)(v)/(vi). Accordingly, the amount is taxable in the year under consideration. The Ld.CIT(A) as briefly stated above relied on the additional fact of tenants being vacated and completion of the project as per the terms and non-filing of returns admitting capital gains even at a later point of time to confirm the action of AO.

11. Before us, Ld.Counsels urged that before entering this agreement, assessees herein have entered into many joint development agreements at various points of time which have not been fructified. In support they filed various copies of the agreements in the Paper Book as under :

1. Copy of the Joint Development entered into between the applicants & 7 others and Mohd. Maher alam Khan dated 30.8.1994.

2. Irrevocable General Power of Attorney executed by the appellants in favour of Mohd. Mahel Alam Khan executed on 30.8.1994.

3. Deed of cancellation of Irrevocable GPA mentioned at S.No.2 above executed on 16.10.1997.

4. Deed dated 23.6.2000 for effecting cancellation of Development Agreement executed on 28.9.1995 in favour of N. Ravi Kumar.

5. Development Agreement executed on 28.6.2000 by the appellants in favour of Sri Dwarakamai Estates P. Ltd.,

6. Development Agreement entered into between the appellants and Smt. P. Chandramathi executed on 24.11.2000.

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12. It was submitted that after cancelling the earlier agreements, assessee entered into a development agreement with M/s. Sun Mark Builders on 04-11-2003. It was further submitted that property was under unauthorised occupation of hut dwellers and a suit was filed before the Land Grabbing Court. The Hon'ble Court stayed the implementation of the development agreement. After prolonged conciliation proceedings, substantial amounts were paid for getting them vacated. Assessees' Counsels referred to payments listed in annexure before the CIT(A). It was submitted that implementation of the development agreement started only after 22-11-2006 when municipal permission was granted. Till then, the developer could not commence any construction. The construction was completed after March, 2010. In the interregnum period, the developer's activity was only clearing the legal impediments. Therefore, assessees are under the impression that they are not liable to tax in the impugned assessment year. Further, it was submitted that assessees were semi-illiterate and having no other incomes, being working as small car mechanics etc., and they are not fully conversant with the legal proceedings. It was also further submitted that the developer had spent lot of amounts on behalf of assessees and therefore according to them, there was no capital gains arising in the transaction. It was submitted that relying on various case laws, the mere permission for development does not attract the provisions of Section 2(47) so as to impose the capital gains tax in the impugned year.

13. Ld. DR, however, supported the orders of the authorities.

14. We have considered the issue and perused the various documents. There is no dispute with the fact that before entering in to this agreement with M/s. Sun Mark Builders, assessees have entered into many agreements which did not fructify. However, that does not mean ITA Nos. 666, 667, 668 & 669 /Hyd/2014 :- 8 -: 718, 719 & 720/Hyd/2014

that this agreement also had the same fate. As seen from the some of the terms of the agreement placed on the Paper Book, particularly Clause 4, 5, 8 and 20 as under the agreement has special terms:

"4 (a) The Developer is hereby permitted by the Owners to develop the Schedule mentioned property by constructing thereon a Residential Complex consisting of Cellor for parking and Ground + Four Upper Floors. The developer shall construct according to the MCH permission cover the entire land or site comprised in the Schedule mentioned property.

(b) It is hereby specifically agreed and declare that the Developer shall construct and completely utilizing fully entitlement areas as sanctioned by the Municipal Corporation of Hyderabad.

(c) That since the portion of the Schedule property is in occupation of tenants, the first party owners shall get them evicted immediately at their cost and accord permission to the Developer to commence the Development work after demolishing the existing structures.

5(a) The Developer hereby agree, covenant and undertakes to handover or deliver 39% of the constructed area i.e., super-built areas which include all shareable areas in common passaged, basement, sewage lines, electrical lines, balconies etc., in all floors of the proposed complex or mutually agreed between the parties to the owners free of cost in lieu of utilisation of their land comprised in the schedule mentioned property for the above said development and construction. The remaining 61% of the constructed area would be retained by the Developer. The earmarking of the portions shall be made after receipt of the approved plans.

(b) The developer shall have the rights over the site and terrace floors of the proposed residential complex to the extent of 61%. In case further floor is permitted to be constructed by the MCH the same shall be apportioned in the above ratio i.e., 39 : 61 between the owners and the developer.

(c) If the owners or the developer received more of constructed areas that her/her/they are/is entitled to in terms of clause (a) above, then the party receiving the extra constructed areas shall pay to the other part cash compensation calculate at the cost of rate. The said cash compensation shall be paid at the time of delivery of constructed areas.

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(d) It is also hereby specifically agreed and declared that the flats constructed areas to be allotted to the owners shall be completed in all respected and the possession of the said flats or constructed areas shall be handed over to the owners.

(e) Any deposits and expenses payable to APSEB Transformer, Services Lines, Sewerage Boards, Water Departments, Generator and Erection charges will be borne by the owners to the extent their share of the property.

(f) It is further agreed that the owners shall pay all the amounts for any extra works such as lofts, shelves, racks and extra-electrical points to the extent of their allotted flats and other built up areas.

8. That the owners hereby undertake to demolish the existing building in the schedule property at their cost and place the developer in actual possession or the schedule mentioned property within a period of one month for the purposes of carrying on the works or constructions and for the purpose of fulfilling the obligations in terms of this agreement. The owners hereby agree not to interfere in the construction or other works being carried out by the developer in or over the schedule mentioned property provided the said works or construction are not inconsistent with the terms and conditions incorporated in this agreement.

20. It is mutually agreed upon and always provided that in the event of the works at the schedule mentioned property suffered or otherwise interrupted due to imposition of statutory restrictions, natural calamities, control or ban imposed on construction material i.e., on sale, distribution and procurement etc., prohibitory orders of any court of law or statutory bodies, the time involved in such processes or eventually, shall be excluded from the stipulated period."

15. Subsequently, the owners have appointed the developer as the General Power of Attorney holder to do, execute and carry out any or all of the following acts as stated therein. One of the conditions was also for payment of rent per month from the date of dismantling of house and if project was not in stipulated time of 3 ½ years, then a penalty of Rs.10,000/- per month shall be paid till the completion of construction. However, six months grace period was allowed. By perusing the above ITA Nos. 666, 667, 668 & 669 /Hyd/2014 :- 10 -: 718, 719 & 720/Hyd/2014

terms of the agreement and the fact that the receipts obtained from the tenants indicate that most of the tenants have been settled and paid by the time agreement was entered into, we are of the opinion that assessees did give possession of the property to the said developer at the time of entering into agreement and the terms of agreement have been fulfilled.

16. The Hon'ble A.P. High Court in the case of Potla Nageswara Rao vs. DCIT [365 ITR 249] held as under:

"Each and every individual case stands on its own footing. Before admitting an appeal the High Court must examine the issue before it on its own merits. The pendency of another matter cannot be a ground to proceed with the matter.

On March 7, 2003, the assessee entered into an agreement with a developer and the plan of the building was approved on March 31, 2003. These dates fell in the previous year 2002-03, relevant to the A.Y. 2003-04. Thus, the Tribunal held that the land being a capital asset was transferred by the assessee to the developer during the A.Y. 2003-04, for construction and it was enough if the assessee had received the right to receive consideration on a later date, so as to attract the exigibility to tax on capital gains during the year 2003-

04. On appeal:

Held, dismissing the appeal that the element of factual possession and agreement are contemplated as transfer within meaning of the section 2(47) of the Income Tax Act, 1961. When the transfer is complete, automatically, consideration mentioned in agreement for sale had to be taken into consideration for purpose of assessment of income for the assessment year when agreement was entered into and possession was given. In the case of the assessee, factually it was found that both the aspects took place in the previous year relevant to the assessment year 2003-04. Hence, the assessee was liable to pay tax on the capital gains for the assessment year 2003-

04."

17. Considering the judgment of the jurisdictional High Court and the facts of the case, we are of the opinion that the agreement entered into by assessees also satisfies the provisions of Section 53A of Transfer of ITA Nos. 666, 667, 668 & 669 /Hyd/2014 :- 11 -: 718, 719 & 720/Hyd/2014

Property Act, and therefore, the said transaction attracts the provisions of Section 2(47) ie. definition of transfer so as to attract capital gains during the impugned year.

18. In the case of Mr. R. Srinivasarao and others ITA.No.1786/Hyd/2012 and others dated 28.08.2014, Binjusaria properties P. Ltd., vs. ACIT ITA.No.157/Hyd/2011 dated 04.04.2014 and also in the case of K. Radhika and others vs. DCIT, Central-II, Hyderabad in ITA.No.208/Hyd/2011, relied on by assessee's counsel the agreements have not been implemented and it was considered that there was no willingness to perform for the purpose of section 53A. In those cases, it was held unless the party has performed or is willing to perform its obligations under the contract and in the same sequence in which these are to be performed, it cannot be said that the provisions of section 53A of the Transfer of Property Act will come into play on the facts of that case. It is further held that unless provisions of section 53A of T.P. Act are satisfied on the facts of case, the transactions in question cannot fall within the scope of deemed transfer under section 2(47)(v) of the I.T. Act. As briefly stated above, the parties have performed the contract as per the terms of the contract. Therefore, the principles laid down in the above case, does not apply to the facts of the present case. Therefore, we are of the opinion that capital gains is correctly imposed in the order under consideration. The action of the Assessing Officer in levying capital gains in the impugned year is consequently upheld.

B. Sale Consideration to be adopted

19. As briefly stated above, the A.O. while considering the sale consideration has taken two amounts for consideration, one amount is 'sale consideration received under the guise of refundable deposit' of Rs.11,00,165 and other 'value of constructed area of flats received in lieu ITA Nos. 666, 667, 668 & 669 /Hyd/2014 :- 12 -: 718, 719 & 720/Hyd/2014

of asset given for development' at Rs.63,71,290 in each case. assessee did contest that both the amounts cannot be taken and value of cost of construction for the builder has to be adopted and not the market price of sale value. As already stated above, Ld. CIT(A) did not adjudicate this issue at all.

20. After considering the rival contentions, we are of the opinion A.O. cannot take both the amounts into consideration as it will be a double addition. To that extent, A.O. action cannot be upheld. It is also assessee's contention that value of constructed area adopted by the A.O. is on the basis of the sale price of certain apartments and assessee's were not given any opportunity to place their submissions. Since most of the orders are exparte, the assessee's contentions that cost of construction of the builder should be adopted has not been examined at all. Therefore, in the interest of justice, we set aside this issue to the file of A.O. with a direction to adopt value of constructed area of flats in view land parted with, after giving due opportunity to the assessee. Assessees contention should be considered in its correct perspective and should not be brushed aside without any valid reason. With this direction, the issue of adopting value of sale consideration is restored to the file of A.O.. Assessees grounds on that are accordingly allowed for statistical purposes.

C. Cost of Acquisition :

21. This issue also require re-examination by the Assessing Officer. Assessing Officer adopted amount of Rs.1,18,835 in each case as cost of acquisition. It was the contention of the assessee that there were buildings on the said land which were demolished and the cost of which was also to be adopted. Therefore, cost of land alone cannot be adopted. Cost of buildings at the time of entering into agreement should ITA Nos. 666, 667, 668 & 669 /Hyd/2014 :- 13 -: 718, 719 & 720/Hyd/2014

be considered. In addition, assessee also claims to have paid lot of amounts to the tenants, unauthorized hutment dwellers as part of clearing the title along with litigation expenses. This expenditure also will form part of cost of acquisition. Subject to verification and furnishing necessary evidences, the A.O. is directed to examine, assessees contentions and allow the indexed cost of acquisition on the basis of facts and law. This issue also accordingly restored to the file of A.O. for fresh consideration.

D. Claim of deduction under section 54 and 54F

22. Since assessees have entered into a development agreement of constructing residential properties in lieu of parting with the residential building, they are eligible for deduction under section 54/54F as the case may be. The A.O. had no occasion to examine this aspect as the assessment was completed exparte. Before the Ld. CIT(A), assessee made this claim which Ld. CIT(A) rejected on the reason that provisions of section 54F are not applicable. Ld. CIT(A) ignored the fact that alternate contention under section 54 is eligible to the assessee. Since we are setting aside the entire computation of capital gains to the file of Assessing Officer, he is directed to examine the aspect of claim of deduction under section 54/54F, keeping in view the judicial pronouncements on the issue by the ITAT/High Court. Assessee should be given due opportunity for making necessary claims. Assessees who have not filed returns i.e., Mohd. Naseer, Mohd. Qaiser, Mohd. Sabir, have filed computation of capital gains as part of paper book, which indicate that there is no capital gains or marginal capital gain which may become less than taxable income. However, this aspect can be examined by the A.O. in the proceedings consequent to this order. All the expenditure claimed by the assessee should be considered and detailed discussion may be made if they are not accepted by the A.O. so ITA Nos. 666, 667, 668 & 669 /Hyd/2014 :- 14 -: 718, 719 & 720/Hyd/2014

that the appellate authorities can examine the correctness of the contentions.

23. With these observations/directions entire computation of capital gain in all the seven cases is restored to the file of A.O. to do according to law and facts. Assessing Officer is free to make necessary enquiries if required. Needless to state again that assessees should be given due opportunity.

24. In all the appeals, grounds to that extent are partly allowed for statistical purposes.

25. In the case of Mohd. Naseer, Mohd. Qaiser, Mohd. Sabir these three assessees have not filed returns of income. Additional contention in these appeals was that the A.O. has not given any notice under section 142(1) before completing the assessments to the best of his judgment with the proposed additions. The Ld. Counsel made elaborate arguments on the issue and relied on various case law including Hon'ble Supreme Court Judgment in the case of Blue Moon Hotels 321 ITR 364. We are afraid that we cannot accept assessees contentions on the issue. First of all, in spite of receiving notices from the A.O. these three assessees have not filed any returns of income. Therefore, failure of filing return of income itself will call for best judgment assessment. Moreover, A.O. has issued notice on 30.03.2011 for which assessees were filed their letter dated 03.05.2011. Since no returns of income were filed by these assessees summons under section 131 dated 15.11.2011 were issued and served on the assessees. Assessees did appear on 22.11.2011 and while recording the statement they were asked why capital gain should not be assessed. Assessee have admitted that they will obtain the PAN and file returns of income. However, they have not filed returns of income as promised. Since the ITA Nos. 666, 667, 668 & 669 /Hyd/2014 :- 15 -: 718, 719 & 720/Hyd/2014

A.O. issued notice under section 148 calling for return and issued a show cause notice on 30.03.2011 and further also summons under section 131 but, there is no compliance by the assessees in filing the returns of income. We are of the opinion that A.O. is well within his rights to complete assessment exparte. Assessee was informed that capital gain will be levied and asked to explain under the provisions of Sec.131 itself. Eventhough a separateshow cause was not issued giving final opportunity this may at best be a procedural lapse. Since we are setting aside the assessments to the A.O. for redoing it, on the issue of computation of capital gains on merits, we are of the opinion that there is no merit in these contentions, as assessee themselves have not filed returns of income in spite of so many notices issued to the assessees. Accordingly, this issue is rejected.

26. In the light of the above, orders of the A.O. in the seven cases are set aside along with the orders of the Ld. CIT(A) and fresh assessments have to be done as per the observations/discussions given above, considering the facts of each case and law on the subject.

27. In the result, appeals of the assessees are considered partly allowed for statistical purposes.

Order pronounced in open Court on 20th March, 2015.

Sd/- Sd/- (SAKTIJIT DEY) (B. RAMAKOTAIAH) JUDICIAL MEMBER ACCOUNTANT MEMBER

Hyderabad, Dated 20th March, 2015.

TNMM & VBP ITA Nos. 666, 667, 668 & 669 /Hyd/2014 :- 16 -: 718, 719 & 720/Hyd/2014

Copy to :

1. Mr. Mohammed Sabir C/o. R. Kankaria & Uttam Singhi, 2. Mr. Mohammed Naseer Chartered Accountants, 5-3-190/CIT(A)- 3. Mr. Mohammed Qaiser 4, Raj Bhavan Road, Above Andhra Bank, Hyderabad - 500 082. 4. Smt. Bilquees Begum C/o. Sri S. Rama Rao,

5. Mr. Mohammed Farooq Advocate, Flat No.102, Shriya's Elegance,

6. Mr. Shaik Mahaboob H.No.3-6-643, St. No.9, Himayatnagar,

7. Smt. Kubra Begum Hyderabad - 500 029.

8. The Income Tax Officer, Ward 8(1), Hyderabad.

9. CIT(A), Vijayawada

10. CIT-II, Hyderabad

11. D.R. ITAT 'B' Bench, Hyderabad

12. Guard File