CA NeWs Beta*: Whether trade discount can be termed as commission u/s 194H

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Tuesday, June 5, 2012

Whether trade discount can be termed as commission u/s 194H


1. ACC Ltd. vs District Valuation Officer & Others
 
Whether reference made to the District Valuation Officer is invalid once the assessment under Section 143(3)
 
There is no provision in the Act which says what would happen to a reference made to the DVO under section 55A which is pending completion at the time of passing the assessment order. Obviously the assessment order cannot be deferred in view of the limitation prescribed for passing the same. The report of the DVO, as and when received by the Assessing Officer, may be acted upon by the income tax authorities and if they do so, the validity of that action can be questioned by the assessee on grounds which he may be advised to take. Section 55A does not in terms create any bar on the DVO proceeding to value the property on the basis of a valid reference made by the Assessing Officer. We need not speculate as to what purpose the report of the DVO would serve if it is received after the completion of the assessment. If any action is taken by the departmental authorities on the basis of the report of the DVO received after the completion of the assessment, such action will be open to challenge by the petitioner and it is at that point of time that the Court may be called upon to examine the validity of the action taken by the revenue authorities.
 
It is in this behalf pointed out in the counter affidavit that the reference to the DVO does not become invalid on the completion of the assessment proceedings before the receipt of the valuation report and that after the receipt of the valuation report after completion of the assessment proceedings, the report would become part of the record which may enable the income tax authorities to take action as permissible under the Act, such as Section 147, Section 263, appellate power under Section 250 or Section 251 etc. It is not necessary to examine the contention of the petitioner that once the assessment proceedings are completed, the pending proceedings under Section 55A become infructuous or invalid or get automatically terminated.
 
 
2. Jagran Prakashan Ltd. vs DCIT(TDS)
 
Whether trade discount can be termed as commission u/s 194H
 
The petitioner has failed to deduct tax at source under section 194H of the Act on the payment received from advertising agencies after allowing 15% trade discount, which is as well a deemed commission.
 
This writ petition by a public Ltd. Company, publishing a Hindi daily newspaper "Dainik Jagaran" has invoked the jurisdiction of this Court under Article 226 of the Constitution of India challenging the initiation of proceedings under sections 201 and 201 (1A) of Income Tax Act, 1961 (hereinafter referred to as 'Act') vide notices dated 19.3.2012 and 21.3.2012 on the allegation that although the petitioner had allowed trade discount of 15% to advertising agencies in the assessment years in question but had failed to deduct the tax at source hence, the petitioner may show cause as to why it may not be declared as an asessee in default of such tax.
 
The petitioner was also informed that Kerala High Court in 325 ITR 205 on the similar issue had decided that advertising agency has acted as an agent of the principal hence trade discount allowed can be considered as commission or brokerage defined under Explanation (i) of Section 194H of the Act. This writ petition was filed in this Court on 23.3.2012 praying for quashing the notice dated 29.3.2012 and 21.3.2012.
 
As Rule 10 of the Indian Newspapers Society Rules clearly provides that advertising agency is free from control or interference from any business or person who owns or controls newspaper, the newspaper agency cannot be treated to be principal and advertising agency as agent.
 
As rules 10 of INS delineate the clear picture of relationship between the newspaper agencies and advertising agencies. It is useful to refer to certain rules of INS which clearly negate the relationship of principal and agent between the newspaper agency and the advertising agency. Under the heading "Rules and Regulations Governing Accreditation of Advertising Agencies", Rule 10 clearly indicates that there is no control of newspapers agency on the advertising agency whereas in a relationship of principal and agent principal retains full control over the activities of agent.
 
It is clear that no foundational fact exists on the basis of which any inference can be drawn that advertising agencies are agent of the petitioners and further advertising agencies render any service to the newspaper. The above two foundational facts being non existent, the proceedings under Section 201/201(1A) of the Act were clearly not permissible.
 
For applicability of Section 194H of the Act i.e. as to whether any payment was made to the advertising agency as commission. The case of the petitioner throughout has been that petitioner has been paying a trade discount at the rate of 15% as per Rule 32 of the Rules. The sample bills, which were collected by the department at the time of survey and are part of the assessment order, mention the total amount paid to advertising agency and the discount provided for and the net bill amount. The petitioner's case is that trade discount has been provided by the petitioner throughout as a part of trade practice. The trade discount is claimed to be given in normal business practice which has been recognised in several cases. Reliance has been placed on the judgment of the Apex Court in the case of Moped India Ltd. vs. Assistant Collector of Central Excise, Nellore and others reported in (1986)1 SCC 125.
 
Held, that there is no liability of deduction of tax at source under Section 194H with regard to trade discount of 15% given to the advertising agency.
 
Must Read: CIT vs Living Media - High Court - ITA 1264/07

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