IN THE ITAT DELHI BENCH ‘E’

Millennium Infocom Technologies Ltd.

v.

Assistant Commissioner of Income-tax, Circle - 6(1), New Delhi

N.K. KARHAIL, JUDICIAL MEMBER

AND K.D. RANJAN, ACCOUNTANT MEMBER

I.T. APPEAL NO. 4465 (DELHI) OF 2004

[Assessment year 2001-02]

January 31, 2008

 

 

 

 

 

Section 40(a)(i) read with sections 195 and 90 of the Income-tax Act, 1961 and Article 26(3) of the DTAA between India and USA - Business disallowance - Interest, etc., payable outside India - Assessment year 2001-02 - Assessee-company was engaged in business of setting up of websites for purposes of E Commerce - For hosting of websites, assessee required servers, which were not available in India at relevant time - For this purpose, it took servers on lease and paid rentals through credit card to four non-resident foreign companies for launching of different websites on their servers located in USA - It claimed deduction of payments in question as a revenue expenditure - Assessing Officer disallowed said amount under section 40(a)(i) on ground that assessee did not deduct any tax at source under section 195 at time of remittance to non resident - Whether since payments made to non-residents on account of rentals for hosting of websites on servers being were not in nature of interest or royalties or fee for technical services or other sum chargeable to tax in India, assessee was not required to deduct tax at source under section 195 while making payments outside India - Held, yes - Whether further in view of provisions of article 26(3) of DTAA between India and USA which neutralizes rigour of provisions of section 40(a)(i), Assessing Officer could not seek to invoke provisions of section 40(a)(i) for deduction while computing profits and gains of business or profession - Held yes

Circulars and Notifications

- Circular No. 759, dated 18-11-1997

- Circular No. 10/2002, dated 9-10-2002

- Circular No. 767/22-5-1998

FACTS

The assessee was engaged in the business of setting up of websites for the purposes of E. Commerce. For hosting of the websites, the assessee required servers, which were not available in India at the relevant time. For this purpose, the assessee took servers on lease and paid rentals through credit card to four non-resident foreign companies for launching of different websites on their servers located in USA. The assessee made payments to the non-resident companies without deduction of tax at source and had claimed deduction of the said payments in question as a revenue expenditure. The Assessing Officer disallowed said amount under section 40(a)(i) on ground that assessee did not deduct any tax at source under section 195 at time of remittance to non resident. The assessee explained to the Assessing Officer that since the payments were made to non-resident foreign companies and the provisions of section 195 were not applicable to foreign/non-resident companies, it was not statutorily liable to deduct tax at source. The Assessing Officer, however, relying on the provisions of section 195 held that the TDS provisions were applicable both to non-resident companies and foreign companies. He, therefore, made disallowance of payments in question under section 40(a)(i).

On appeal, the Commissioner (Appeals) upheld the action of the Assessing Officer.

On second appeal:

HELD

Under section 40(a)(i), relevant to the assessment year 2001-02, in the case of any assessee, any interest (not being interest on a loan issued for public subscription before 1-4-1938, royalty, fees for technical services or other sum chargeable under this Act, which is   payable outside India, on which tax has not been paid or deducted under Chapter XVII-B, shall not be deducted in computing the income chargeable under the head ‘profits and gains of business or  profession’.  Proviso to sub-clause (i) further says that where in respect of such sum tax has been paid or deducted under Chapter XVII-B in any subsequent year, such sum shall be allowed as deduction in computing the income of the previous year in which such tax has been paid or deducted. Sub- clause (ia) which contains identical provisions in respect of payments made to a resident, has been inserted by the Finance (No. 2) Act, 2004, with effect from 1-4-2005. In this sub-clause words ‘rent, royalty’ have been  inserted with effect from 1-4-2006. Provisions of sub-clause (i) deals with the payments made outside India or to, a non resident; whereas sub-clause (ia) deals with the payments made to residents. Thus with effect from 1-4-2005 payments made to a resident on account of interest, or fee for technical services and royalty with effect from 1-4-2006 will also not be allowed as deduction unless tax at source has been deducted. From the language employed in sub-clause (i) it is clear that the payments made outside India or to a non resident on account of any interest, royalty, fee for technical services or other sum should be chargeable to tax in India. In the instant case, the payments had been made to non residents on account of rentals for hosting the websites on their servers located in USA. Therefore, the question for consideration arose as to whether payments made in question were in nature of interest or royalty or fee for technical services or other sum chargeable to tax in India. Admittedly, payments made were not in nature of interest, as these were not relatable to any loan/ trade advances. [Para 8]

The definition of ‘Fees for technical services’ as defined in Explanation 2 to section 9(1)(vii) shows that consideration paid for rendering of any managerial, technical or consultancy services, as also the consideration paid for the provision of services of technical or other personnel, would be regarded as fees paid for ‘Technical services’ The definition excludes from its ambit the consideration paid for construction, assembly, or mining or like project undertaken by the recipient, as also consideration which would constitute income of the recipient chargeable under the head ‘Salaries’. The Madras High Court in the case of Skycell Communication Ltd. v. Dy. CIT [2001]/19 Taxman 496/251 ITR 53 had examined the scope of term technical services. It was held in said case that installation and operation of sophisticated equipments with a view to earn income by allowing customers to avail of the benefits of the user of such equipments does not result in the provision for technical service to the customer for a fee.  On applying the above stated reasoning to the facts of the instant case, it could be safely concluded that.  Therefore, providing of space on the servers by the non residents for the purpose of hosting of the website would not result in the provision for technical service to the assessee for a fee. Therefore, the payments were not made for fees for technical services liable to be taxed in India.   [Paras 8.1 and 8.2]

Now the question for consideration arose as to whether payment of rentals for hosting of websites on the servers amounted to royalty. Explanation to section 40(a)(i) states that for the purposes of sub-clause (i) ‘royalty’ shall have the same meaning as in Explanation 2 to clause (vi) of sub-section (1) of section 9.  From the definition of royalty as mentioned in Explanation 2 to clause (vi) of  section 9(1) for and upto the assessment year 2001-02 it is clear that none of the clauses of Explanation take into its ambit the consideration paid for renting of space for hosting of websites on servers. However, clause (iva) to Explanation 2, which was inserted by the Finance Act, 2001, with effect from 1-4-2002, reads as. The use or right to use any industrial, commercial or scientific equipment but not including the amounts referred to in section 44BB.

Thus with effect from 1-4-2002, the consideration for use or right to use industrial commercial or a scientific equipment is royalty.  [Paras 8.3 and 8.4]

The legislative intention for insertion of clause (iva) in Explanation 2 to section 9(1)(vi) can be traced from the memorandum explaining the provisions of the Finance Bill, 2001. From plain reading of the memorandum explaining the provisions of the Finance Bill, 2001, it is clear that prior to the amendment, the consideration for the use of, or the right to use, industrial, commercial or scientific equipment was not included in the definition of ‘royalty’ in Explanation 2 and consequently the income from the leasing of industrial, commercial or scientific equipment became taxable in the source country as business income from the assessment year 2002-03 and onwards.  [Para 8.5]

As per paragraph 1 of article 12, the DTAA between India and USA, dated 20-12-1990, royalties and fees for included services arising in a Contracting State and paid to a resident of other Contracting State may be taxed in that other State. However, as per paragraph 2 of article 12 such royalties and fees for included services may also be taxed in the Contracting State in which they arise and according to the laws of that State; but if the beneficial owner of the royalties or fees for included services is a resident of other Contracting State, the tax so charged shall not exceed the specified percentage mentioned in this article. Also paragraph 3(b) of article 12 takes into its ambit the payments of any kind received as consideration for the use of, or the right to use any industrial, commercial or scientific , equipment other than equipments relating to Shipping and Air Transport described in paragraph 2(c) or 3 of article 8. Though the DTAA between India and USA provides for taxing of royalties for the use of, or the right to use any industrial, commercial or scientific equipment in the Contracting State in which they arise and according to the laws of that State but the same could not be taxed in India upto assessment year 2001-02 as clause (iva) of Explanation 2 to section 9(l)(vi) was inserted with effect from 1-4-2002.   [Para 8.6]

The Central Board of Direct Taxes in the Circular No. 759, dated 18-11-1997 in F. No.500/152/96-FTD dispensed with the requirement of no objection certificate to be obtained from the Assessing Officer at the time of remittance outside India. From the said circular it is clear that at the time of remittance, the only requirement on the part of the assessee (the remitter) is to file an undertaking along with a certificate of the accountant to the Reserve Bank of India (RBI) who  in turn shall forward a copy thereof to the Assessing Officer. Further the CBDT in Circular No 767, dated 22-5-1998 reiterated the requirements to be fulfilled as in earlier circular No. 759, dated 18-11-1997. However in Para 4 of this circular it has been clarified that circular No. 759 would cover those remittances for which RBI had prescribed the production of a no objection certificate from the income-tax authorities under the Exchange Control Manual. Further, if an order under section 195(2) has been obtained by a person responsible for deducting tax, the new procedure of filing an undertaking along with a certificate prescribed in circular No 759 would not be applicable. Nothing has been produced by the revenue that no objection certificate from income-tax authorities was required to be filed by the assessee. Again CBDT in Circular No 10/2002 dated 9-10-2002 reiterated the submitting of an undertaking along with a certificate from a chartered accountant before RBI at the time of the remittances to non residents. In this circular new formats of the undertaking by the asseessee and certificate from an accountant have been prescribed. In undertaking furnished before RBI (a copy thereof to be forwarded to the Assessing Officer by RBI), the assessee has to undertake certain responsibility. From the formate of the certificate to be issued by the chartered accountant, it is clear that he is duty bound to examine the books of account for ascertaining the nature of the remittance. The certificate contains the amount of remittance; name and complete address of the person to whom the remittance to be made; the rate at which the tax is to be deducted at source; the amount of tax deducted and credited to the Government. Under the new procedure, the revenue can recover the tax along with interest, if any, from the assessee in a case the tax authorities later on find that short or no deduction of tax at source was made. The assessee is also liable for penalty/prosecution for the default committed by him. Thus CBDT with effect from 18-11-1997 prescribed a new procedure for the purposes of the remittance of payments under which issue of no objection certificate under section 195(2) by the Income-tax authorities has been dispensed with.   [Paras 8.7 and 8.10]

However, under section 195(2) the person responsible for paying any such sum, other than salary, chargeable under the Act to a non resident considers that the whole of such sum would not be income chargeable in the case of the recipient, he may make application to the Assessing Officer to determine, by general or special order, the appropriate portion of such sum so chargeable, and upon such determination, tax shall be deducted under sub-section (1) only on that proportion of the sum which is chargeable. The Supreme Court in the case of Transmission Corporation of Andhra Pradesh Ltd. v CIT [1999] 239 ITR587/105 Taxman 742 has clearly laid down the principle that the obligation of the assessee to deduct tax under section 195 is limited only to the appropriate proportion of income chargeable under the Act. This leaves no doubt that at the time of making payments of any sums to non-residents, the nature of the remittance has to be determined for the purposes of deduction of tax at source. The CBDT in three circulars i.e. Circular Nos. 759, dated
18-11-1997; 767, dated 22-05-1998; and 10 of 2002, dated 9-10-2002 have entrusted this task to the chartered accountant. Only in the cases where the person responsible for paying any such sum, other than salary, chargeable under the Act to a non resident considers that the whole of such sum would not be income chargeable in the case of the recipient, he is obliged to make application to the Assessing Officer under section 195(2) to determine the appropriate portion of such sum so chargeable and tax shall be deducted under sub section (1) only on that proportion of the sum which is chargeable. Even in the cases where lower tax has been deducted or no tax deducted, the assessee by filing an undertaking before the RBI (addressed to the Assessing Officer) has made himself liable not only for payment of tax on such remittances but also for penalty and prosecution for the defaults committed by him for non deduction or lower deduction of tax at source.
 [Para 8.11]

Thus, the payments made to non-residents were neither in the nature of interest  nor fee for technical services or royalty. Since the payment for use of space in servers was not in nature of royalty and income arising on use of, or the right to use, industrial, commercial or scientific equipment was not royalty prior to the amendment of section 9(1) by the Finance Act, 2001 with effect from 1-4-2002, within the meaning of provisions of Explanation 2 to section 9(vi) of the Act, the same was to assessed in other Contracting State i.e. USA as per paragraph 1 of Article 12 of DTAA and not in India. [Para 8.12]

The assessee also submitted that it was protected under article 26(3) of India-US DTAA. Article 26(3) is a general clause providing for indirect discrimination against a non resident. It reads as except where the provisions of paragraph 1 of Article 9 (Associated Enterprises), paragraph 7 of article 11 (Interest), or paragraph 8 of article l2 (Royalties and Fees for Included Services) apply , interest, royalties, and other disbursements paid by a resident of a Contracting State to a resident of a other Contracting state shall, for the purposes of determining the taxable profits of the first mentioned resident , be deductible under the same conditions as if they had been paid to a resident of the first mentioned State. Apparently the provisions of paragraph 1 of article 9 (Associated Enterprises) and paragraph 7 of article 11 (Interest) of DTAA were not applicable to facts of the instant case. Paragraph 8 of article 12 (Royalties and Fees for Included Services) deals with a situation where, by reason of a special relationship between the payer and the beneficial owner or between them and some other person, an excess payment is made on account of royalties and fees for included services, such excess payment will be taxed according to laws of each Contracting State having due regard to the other provisions of the Convention.  In the instant case, the parties were neither related; nor was the issue relating to excess payment involved. Thus assessee’s case also did not fall under paragraph 8 of article 12 (Royalties and Fees for Included Services). [Paras 8.13 and 8.14]

The provisions of section 40(a)(i), as it stood prior to its amendment by the Finance (No 2) Act, 2004 with effect from 1-4-2005, applied to the payments by an assessee outside India to a non resident only. Sub- clauses(i), (ia) and (ib) of clause (a) of section 40 were substituted for sub clause (i) by the Finance (No 2) Act, 2004 with effect from 1-4-2005. While sub-clause (i) still applies to the payments by an assessee outside India to a non resident but sub-clause(ia) applies to payments made to resident assessee. The terms ‘rent, royalty’ were inserted in sub- clause (ia) of clause (a) of section 40 by the Taxation laws (Amendment) Act, 2006 with retrospective effect from 1-4-2006. Thus, with effect from 1-4-2005, the provisions of section 40(a) apply equally both in the case of resident and non resident except payments for rent and royalty which are applicable with effect from 1-4-2006. [Para 8.15]

Now the question for consideration was as to whether the resident assessee could take advantage of provisions of article 26(3) of DTAA. The provisions of section 40(a)(i), as it existed prior to its amendment by the Finance (No 2) Act, 2004, with effect from 1-4-2005 and subsequent amendment by the Taxation laws (Amendment) Act, 2006 with retrospective effect from 1-4-2006, provided for disallowance of payments made to a non resident only where tax is not deducted at source at the time of remittance. However, a similar payment to a resident does not result in disallowance in the event of non deduction of tax at source. Thus a non resident left with a choice of dealing with a resident or a non resident in business would opt to deal with a resident owing to the provisions of section 40(a)(i). To this extent the non resident is discriminated. Article 26(3) of Indo-US DTAA seeks to provide relief against such discrimination by saying that deduction should be allowed on the same condition as if the payment is made to a resident. Thus, this clause in DTAA neutralizes the rigour of the provisions of section 40(a)(i) of the Act. In this regard it would be relevant to refer to the provisions of section 90(2). Hence, by virtue of the provisions of section 90(2), the law which is beneficial to the assessee to whom DTAA applies, should be followed.  [Para 8.16]

Therefore, in view of the provision of article 26(3) of DTAA, the Assessing Officer could not seek to invoke the provisions of section 40(a)(i) for deduction while computing the profits and gains of business or profession. Therefore, it was to be held that the payments made on account of rentals for hosting of websites on servers are not in nature of interest or royalties or fee for technical services or other sum chargeable to tax in India. The Central Board of Direct Taxes had revised the procedure for deduction of tax at source on remittances made out of the country. The provisions DTAA were also in favour of the assessee. Accordingly, the assessee was not required to deduct tax at source under section 195 while making payments outside India. Therefore, the appeal was to be allowed.  [Para 8.17]

 

EDITOR’S NOTE

(i) Where the assessee had an independent investment division and had earned exempted income viz dividend from investments made in the companies, the Assessing Officer was required to ascertain the actual expenditure incurred out of expenditure made on investment division which could be related for earning of exempted income and only such expenditure could be disallowed under section 14A. 

(ii) Where the assessee in earlier years had given certain amount to its employees by way of loan and in the relevant previous year had written off the same in the books of account on the request of the employees and had claimed deduction of the said amount as business expenditure, since no material had been brought on record to prove the business expediency, the loan given to various employees in earlier years and writing of the same would not constitute the expenditure incurred for the purpose of business and therefore, the Assessing Officer was justified in disallowing assessee’s claim. 

CASE REVIEW

- Skycell Communications Ltd. v. Dy, CIT [2001] 251 ITR 53/119 Taxman 496 [Para 8.2]; Transmission Corporation of Andhra Pradesh Ltd. v. CIT [1999] 239 ITR 587 (SC)/105 Taxman 742 [Paras 8.11]- Followed.