Supreme Court of India
COMMISSIONER OF INCOME TAX-VIversusVIRTUAL SOFT SYSTEMS LTD.
- Citation
- 2018 INSC 399
- Decided
- 24 April 2018
- Disposal
- Appeal(s) allowed
- Bench
- R K AGRAWAL
Holding
Lease equalisation charges representing capital recovery are not taxable income and may be deducted, as the ICAI’s Guidance Note, endorsed by Section 211 of the Companies Act, provides a valid method of computing real income and there is no express bar in the Income Tax Act.
Summary
Virtual Soft Systems Ltd claimed a deduction for lease equalisation charges in its 1999-2000 income tax return. The Assessing Officer disallowed the deduction, but the Income Tax Appellate Tribunal allowed it, a decision upheld by the High Court. The Revenue appealed to the Supreme Court, questioning whether such a deduction is permissible under the Income Tax Act, 1961. The Court held that the Institute of Chartered Accountants of India (ICAI) is an expert body whose Guidance Note on lease accounting is a valid accounting standard, and Section 211 of the Companies Act, 1956 makes such standards binding until superseded. It further observed that bifurcating lease rentals into capital recovery and finance income reflects the substance of the transaction and is analogous to separating principal and interest on a loan, with only the finance income being taxable. Since there is no express prohibition in the Income Tax Act, the lease equalisation charge is not taxable income and the deduction is allowable. Consequently, the appeal was dismissed and the respondent’s right to claim the deduction was affirmed.
Issues considered
- Whether lease equalisation charges can be deducted under the Income Tax Act, 1961.
- Whether the ICAI Guidance Note on accounting for leases is binding for tax assessment purposes.
- Whether Section 211 of the Companies Act, 1956 mandates the application of ICAI accounting standards in computing taxable income.
- Whether the bifurcation of lease rental into capital recovery and finance income is permissible under the Income Tax Act.
Legislation cited
Subjects
Lease accountingLease equalisationIncome tax deductionICAI Guidance NoteSection 211 Companies ActSubstance over formFinance leaseTaxation of lease rentals
Judgment
[2018] 5 S.C.R. 595 595
COMMISSIONER OF INCOME TAX-VI A
v.
VIRTUAL SOFT SYSTEMS LTD.
(Civil Appeal No. 4358 of 2018)
APRIL 24, 2018 B
[R. K. AGRAWAL AND ABHAY MANOHAR SAPRE, JJ.]
Income Tax Act, 1961 – Deduction on account of lease
equalization charges from lease rental income – Entitlement for –
Held: The bifurcation of the lease rental is, by no stretch of C
imagination, an artificial calculation and, therefore, lease
equalization is an essential step in the accounting process to ensure
that real income from the transaction in the form of revenue receipts
only is captured for the purposes of income tax – Moreover, there is
no express bar in the IT Act which bars the bifurcation of the lease
rental – This bifurcation is analogous to the manner in which a D
bank would treat an EMI payment made by the debtor on a loan
advanced by the bank – The repayment of principal would be a
balance sheet item and not a revenue item – Only the interest earned
would be a revenue receipt chargeable to income tax – Hence, whole
revenue from lease would not be subjected to tax under the IT Act – E
Respondent is entitled for bifurcation of lease rental as per the
accounting standards prescribed by the ICAI – Chartered
Accountants Act, 1949.
Chartered Accountants Act, 1949 – Guidance note issued by
the Institute of Chartered Accountants of India (ICAI) – Reliability F
of – Held: ICAI is a recognized expert body vested with the
authority to recommend accounting standards – The method of
accounting followed, as derived from the ICAI’s Guidance Note, is
a valid method of capturing real income based on the substance of
finance lease transaction.
G
Companies Act, 1956 – s.211 – Accounting standards as
prescribed by ICAI to prevail until the accounting standards are
prescribed by the Central Government.
H
595
596 SUPREME COURT REPORTS [2018] 5 S.C.R.
A Disposing of the appeals, the Court
HELD: 1.1 The ICAI is an expert body, created by the
Parliament under the Chartered Accountants Act, 1949. The
ICAI’s publication on the subject indicates that the Guidance
Note on Accounting for Leases was issued by it for the first time
B in 1988 which was later on revised in 1995. The Guidance Note
reflects the best practices adopted by the accountants throughout
the world. The ICAI is a recognized body vested with the
authority to recommend accounting standards for ultimate
prescription by the Central Government in consultation with the
National Advisory Committee of Accounting Standards for the
C presentation of true and fair financial statements. [Para 8]
[601-C-D]
1.2 Section 211 of the Companies Act, 1956 as it stood
before the amendment dealt with “the Form and contents of
balance-sheet and profit and loss account”. Sub clause (3C) of
D Section 211 was added vide 1999 amendment with retrospective
effect. The purpose behind the amendment in Section 211 of the
Companies Act, 1956 was to give clear sight that the accounting
standards, as prescribed by the ICAI, shall prevail until the
accounting standards are prescribed by the Central Government
E under this sub-section. The purpose behind the accounting
standards was to arrive at a computation of real income after
adjusting the permissible deprecation. It is not disputed that these
accounting standards are made by the body of experts after
extensive study and research. [Paras 9, 10] [601-E; 602-A-B]
F 2.1 The method of accounting provided in the Guidance
Note of 1995, on the one hand, adjusts the inflated cost of interest
of the assets in the balance sheet. Secondly, it captures “real
income” by separating the element of capital recovery (essentially
representing repayment of principal amount by the lessee, the
principal amount being the net investment in the lease), and the
G finance income, which is the revenue receipt of the lessor as
remuneration/reward for the lessor’s investment. As per the
Guidance Note, the annual lease charge represents recovery of
the net investment/fair value of the asset lease term. The finance
income reflects a constant periodic rate of return on the net
H investment of the lessor outstanding in respect of the finance
COMMISSIONER OF INCOME TAX-VI v. VIRTUAL SOFT 597
SYSTEMS LTD.
lease. While the finance income represents a revenue receipt to A
be included in income for the purpose of taxation, the capital
recovery element (annual lease charge) is not classifiable as
income, as it is not, in essence, a revenue receipt chargeable to
income tax. [Para 12] [604-C-E]
2.2 The method of accounting followed, as derived from B
the ICAI’s Guidance Note, is a valid method of capturing real
income based on the substance of finance lease transaction. The
rule of substance over form is a fundamental principle of
accounting, and is in fact, incorporated in the ICAI’s Accounting
Standards on Disclosure of Accounting Policies being accounting
standards which is a kind of guidelines for accounting periods C
starting from 01.04.1991. It is a cardinal principle of law that the
difference between capital recovery and interest or finance income
is essential for accounting for such a transaction with reference
to its substance. If the same was not carried out, the Respondent
would be assessed for income tax not merely on revenue receipts D
but also on non-revenue items which is completely contrary to
the principles of the IT Act and to its Scheme and spirit.
[Para 13] [604-F-H]
2.3 The bifurcation of the lease rental is, by no stretch of
imagination, an artificial calculation and, therefore, lease E
equalization is an essential step in the accounting process to
ensure that real income from the transaction in the form of
revenue receipts only is captured for the purposes of income
tax. Moreover, there is no express bar in the IT Act which bars
the bifurcation of the lease rental. This bifurcation is analogous
to the manner in which a bank would treat an EMI payment made F
by the debtor on a loan advanced by the bank. The repayment of
principal would be a balance sheet item and not a revenue item.
Only the interest earned would be a revenue receipt chargeable
to income tax. Hence, there is no force in the contentions of the
Revenue that whole revenue from lease shall be subjected to tax G
under the IT Act. [Para 14] [605-A-C]
Commissioner of Income Tax-VII, New Delhi v. Punjab
Stainless Steel Industries (2014) 15 SCC 129 – relied
on.
H
598 SUPREME COURT REPORTS [2018] 5 S.C.R.
A 3. The main contention of the Revenue is that the
Respondent cannot be allowed to claim deduction regarding lease
equalization charges since as such there is no express provision
regarding such deduction in the IT Act. The IT Act is silent on
such deduction. For such calculation, the Respondent has to take
course of Guidance Note prescribed by the ICAI if it is available.
B
Only after applying such method which is prescribed in the
Guidance Note, the Respondent can show fair and real income
which is liable to tax under the IT Act. Therefore, it is wrong to
say that the Respondent claimed deduction by virtue of Guidance
Note rather it only applied the method of bifurcation as prescribed
C by the expert team of ICAI. Further, a conjoint reading of Section
145 of the IT Act read with Section 211 (un-amended) of the
Companies Act make it clear that the Respondent is entitled to
do such bifurcation and there is no illegality in such bifurcation
as it is according to the principles of law. Moreover, the rule of
interpretation says that when internal aid is not available then for
D
the proper interpretation of the Statute, the court may take the
help of external aid. If a term is not defined in a Statute then its
meaning can be taken as is prevalent in ordinary or commercial
parlance. [Paras 16, 17] [605-F-H; 606-A-C]
Case Law reference
E
(2014) 15 SCC 129 relied on Para 15
CIVIL APPELLATE JURISDICTION : Civil Appeal No. 4358
of 2018.
From the Judgment and Order dated 07.02.2012 of the High Court
F of Delhi at New Delhi in ITA No.404/2011
WITH
Civil Appeal Nos. 4359, 4360, 4361, 4365, 4362, 4363, 4364, 4366-
4367, 4368, 4370, 4369, 4371, 4372, 4373, 4375, 4374 and 4376 of 2018.
G K. Radhakrishnan, Sr. Adv., Om Prakash Shukla, H.R. Rao, Alok
Shukla, Yajur Sharma (for Mrs. Anil Katiyar), Advs. for the Appellant.
Kavin Gulati, Sr. Adv., Santosh Kumar-I, Jagmohan Sharma, S.
Krishnan, Mrs. Rani Chhabra, Nikhil Nayyar, Ms. Pritha Sri Kumar,
Ms. Arunima Kedia, Advs. for the Respondent.
H
COMMISSIONER OF INCOME TAX-VI v. VIRTUAL SOFT 599
SYSTEMS LTD.
The Judgment of the Court was delivered by A
R. K. AGRAWAL, J.
SLP (C) No. 25006 of 2012
1. Leave granted.
2. This batch of appeals has been filed against the impugned B
judgment and order dated 07.02.2012 passed by the High Court of Delhi
at New Delhi in ITA Nos. 216, 398, 403, 404 and 680 of 2011 whereby
the Division Bench of the High Court upheld the decision of the Income
Tax Appellate Tribunal (in short ‘the Tribunal’) dated 19.02.2010. Since
the moot question of law in all these appeals is akin, hence, vide this C
common judgment, all the appeals would stand disposed of.
3. In order to appreciate the controversy at hand, it is pertinent to
allude to the relevant facts in a summarized way for the proper insightful
of the instant case.
(a) The appellant herein is the Income Tax Department, on the D
other hand, the Respondent - M/s Virtual Soft Systems Ltd. is a company
registered under the provisions of the Companies Act, 1956.
(b) On 29.12.1999, the Respondent filed return of income for the
Assessment Year 1999-2000 declaring loss of Rs 70,24,178/- while
claiming an amount of Rs 1,65,12,077/- as deduction for lease equalization E
charges.
(c) On scrutiny, the Assessing Officer, after perusal of the return
and hearing the parties, vide Assessment Order dated 28.01.2005
disallowed deduction claimed as the lease equalization charges amounting
to Rs. 1,65,12,077/- and added the same to the income of the Respondent F
under the Income Tax Act, 1961 (in short ‘the IT Act’).
(d) Being aggrieved with the said Assessment Order, the
Respondent preferred an appeal before the Commissioner of Income
Tax (Appeals). Learned CIT (Appeals), vide order dated 15.09.2005,
upheld the order of the Assessing Officer and dismissed the appeal. G
(e) Being dissatisfied, the Respondent preferred an appeal before
the ITAT. Vide order dated 19.02.2010, the ITAT allowed the appeal of
the Respondent while setting aside the orders passed by Learned CIT
(Appeals) and the Assessing Officer.
H
600 SUPREME COURT REPORTS [2018] 5 S.C.R.
A (f) Being aggrieved, the Revenue took the matter before the
High Court. The High Court, vide judgment and order dated 07.02.2012,
dismissed the appeals at the preliminary stage while confirming the
decision of the ITAT.
(g) Hence, this instant appeal has been filed before this Court by
B the Revenue.
4. We have given our thoughtful consideration to the submissions
of learned senior counsel for the parties and perused the relevant records
of the case.
Point(s) for consideration:-
C
5. The short question that arises for consideration before this Court
is whether the deduction on account of lease equalization charges from
lease rental income can be allowed under the Income Tax Act, 1961, on
the basis of Guidance Note issued by the Institute of Chartered
Accountants of India (ICAI)?
D
Rival submissions:-
6. At the outset, learned senior counsel for the Revenue contended
that the lease equalization charge is an additional deduction debited to
Profit and Loss Account (P&L) in addition to the depreciation claimed
in books so as to make it equal to capital recovery. This is an artificial
E
calculation which bifurcates lease rental to capital recovery and interest
component. Learned senior counsel further contended that in fact the
entire lease income constitutes income of the assessee. Also, there is
no concept of deduction regarding the lease equalization charges under
the IT Act. Hence, learned senior counsel contended that impugned
F decision of the High Court is perverse and is liable to be set aside.
7. On the other hand, learned senior counsel for the Respondent
submitted that this issue is no longer res integra. Now, it is a settled
principle that a Guidance Note issued by the ICAI carries great weight
and by adopting a method of accounting prescribed in such a Guidance
G Note, in order to compute real income and offering the same for taxation,
cannot be disregarded by the Assessing Officer unless such action falls
within the scope and ambit of Section 145(3) of the IT Act. Further, it
was submitted that the lease equalization charge was nothing but a method
of adjusting the depreciation claimed in the books of accounts to enable
H
COMMISSIONER OF INCOME TAX-VI v. VIRTUAL SOFT 601
SYSTEMS LTD. [R. K. AGRAWAL, J.]
the Respondent to represent its real income by adopting an accounting A
methodology which had surely the seal of approval of a professional
body such as the ICAI. Learned senior counsel finally submitted that
the judgment passed by the High Court is well-versed and within the
parameters of law and no interference is sought for by this Court in the
matter.
B
Discussion:-
8. Prior to critically examining the case, it would be appropriate to
have an understanding and significance of the Guidance Note issued by
the ICAI. The ICAI is an expert body, created by the Parliament under
the Chartered Accountants Act, 1949. The ICAI’s publication on the C
subject indicates that the Guidance Note on Accounting for Leases was
issued by it for the first time in 1988 which was later on revised in 1995.
The Guidance Note reflects the best practices adopted by the accountants
throughout the world. The ICAI is a recognized body vested with the
authority to recommend accounting standards for ultimate prescription
by the Central Government in consultation with the National Advisory D
Committee of Accounting Standards for the presentation of true and fair
financial statements.
9. Section 211 of the Companies Act, 1956 as it stood before the
amendment dealt with “the Form and contents of balance-sheet and
profit and loss account”. Sub clause (3C) of Section 211 was added vide E
1999 amendment with retrospective effect. The relevant portion of
Section 211 of the Companies Act is reproduced herein as under:
“(3C) For the purposes of this section, the expression “accounting
standards” means the standards of accounting recommended by
the Institute of Chartered Accountants of India constituted under F
the Chartered Accountants Act, 1949 (38 of 1949), as may be
prescribed by the Central Government in consultation with the
National Advisory Committee on Accounting Standards established
under sub-section (1) of section 210A:
Provided that the standards of accounting specified by the Institute G
of Chartered Accountants of India shall be deemed to be the
accounting standards until the accounting standards are prescribed
by the Central Government under this sub-section.”
(Emphasis supplied by us)
H
602 SUPREME COURT REPORTS [2018] 5 S.C.R.
A 10. The purpose behind the amendment in Section 211 of the
Companies Act, 1956 was to give clear sight that the accounting standards,
as prescribed by the ICAI, shall prevail until the accounting standards
are prescribed by the Central Government under this sub-section. The
purpose behind the accounting standards was to arrive at a computation
of real income after adjusting the permissible deprecation. It is not
B
disputed that these accounting standards are made by the body of experts
after extensive study and research.
11. At this stage, it would be pertinent to reproduce the relevant
provisions of the Guidance Note on Accounting for Leases, revised in
1995, which is as under:-
C
“Accounting for leases in the Books of a lessor
Finance Leases
9. Assets leased under finance leases should be disclosed as
“Assets given on lease”, as a separate section under the head
“Fixed Assets” in the balance sheet of the lessor. The classification
D of ‘Assets given on lease’ should correspond to that adopted in
respect of other fixed assets. In addition to the particulars required
by statute, e.g., Schedule VI to the Companies Act, 1956,
particulars relating to Lease Adjustment Account should be
disclosed as stated in Para 11.
E 10. Lease rentals (those received and those due but not received)
under a finance lease should be shown separately under ‘Gross
Income’ in the profit and loss account of the relevant period.
11. It is appropriate that against the lease rental, a matching lease
annual charge is made to the profit and loss account. This annual
F lease charge should represent recovery of the net investment/
fair value of the leased asset over the lease term. The said charge
should be calculated by deducting the finance income for the period
(as per para 12 below) from the lease rental for that period. This
annual lease charge would comprise (i) minimum statutory
G depreciation (e.g., as per the Companies Act, 1956) and (ii) lease
equalization charge, where the annual lease charge is less than
minimum statutory depreciation. However, where annual lease
charge is less than minimum statutory depreciation, a lease
equalization credit would arise. In this regard the following
accounting entries/disclosure should be made.
H
COMMISSIONER OF INCOME TAX-VI v. VIRTUAL SOFT 603
SYSTEMS LTD. [R. K. AGRAWAL, J.]
(a) A separate Lease Equalization Account should be opened A
with a corresponding debit or credit to Lease Adjustment
Account, as the case may be.
(b) Lease Equalisation Account should be transferred every
year to the Profit and Loss Account and disclosed separately
as a deduction from/addition to gross value of lease rentals B
shown under the head “Gross Income”.
(c) Statutory depreciation should be shown separately in the
profit and loss account. Accumulated statutory depreciation
should be deducted from the original cost of the leased asset
in the balance sheet of the lessor to arrive at the net book C
value.
(d) Balance standing in Lease Adjustment Account should be
adjusted in the net book value of the leased assets. The
amount of adjustment in respect of each class of fixed assets
may be shown either in the main balance sheet or in the D
Fixed Assets Schedule as a separate column in the section
related to leased assets.
(e) The aggregate amount included under Lease Adjustment
Account on account of lease equalisation credits should be
disclosed separately. E
The method of income measurement suggested in this paragraph,
is in consonance with the inherent nature of a finance lease.
The above method is illustrated in the Appendix to this Guidance
Note.
F
12. The finance income for the period should be calculated by
applying the interest rate implicit in the lease to the net investment
in the lease during the relevant period. This method would ensure
recognition of net income in respect of a finance lease at a constant
periodic rate of return on the lessor’s net investment outstanding
in the lease. However, some lessor use a simpler method for G
calculating the finance income for each of the periods comprising
the lease term by appropriating the total finance income from the
lease in the ratio of minimum lease payments outstanding during
each of the respective periods comprising the lease term. (The
total finance income from the lease is the difference between the
H
604 SUPREME COURT REPORTS [2018] 5 S.C.R.
A aggregate minimum lease payments receivable over the lease term
and the fair value of the leased asset at the inception of the lease.)
This method may be used where the finance income in respect of
all individual periods as per this method approximate the finance
income for the corresponding periods determined according to
the former method. It is however clarified that where this method
B
is used, overdue lease rentals, i.e., lease rentals fallen due but not
collected should not be taken into account for determining the
amount of minimum lease payments outstanding during each of
the respective periods comprising the lease term.”
12. At the first look, it appears that the method of accounting
C provided in the Guidance Note of 1995, on the one hand, adjusts the
inflated cost of interest of the assets in the balance sheet. Secondly, it
captures “real income” by separating the element of capital recovery
(essentially representing repayment of principal amount by the lessee,
the principal amount being the net investment in the lease), and the finance
D income, which is the revenue receipt of the lessor as remuneration/reward
for the lessor’s investment. As per the Guidance Note, the annual lease
charge represents recovery of the net investment/fair value of the asset
lease term. The finance income reflects a constant periodic rate of return
on the net investment of the lessor outstanding in respect of the finance
lease. While the finance income represents a revenue receipt to be
E included in income for the purpose of taxation, the capital recovery
element (annual lease charge) is not classifiable as income, as it is not, in
essence, a revenue receipt chargeable to income tax.
13. The method of accounting followed, as derived from the ICAI’s
Guidance Note, is a valid method of capturing real income based on the
F substance of finance lease transaction. The rule of substance over form
is a fundamental principle of accounting, and is in fact, incorporated in
the ICAI’s Accounting Standards on Disclosure of Accounting Policies
being accounting standards which is a kind of guidelines for accounting
periods starting from 01.04.1991. It is a cardinal principle of law that the
G difference between capital recovery and interest or finance income is
essential for accounting for such a transaction with reference to its
substance. If the same was not carried out, the Respondent would be
assessed for income tax not merely on revenue receipts but also on non-
revenue items which is completely contrary to the principles of the IT
Act and to its Scheme and spirit.
H
COMMISSIONER OF INCOME TAX-VI v. VIRTUAL SOFT 605
SYSTEMS LTD. [R. K. AGRAWAL, J.]
14. The bifurcation of the lease rental is, by no stretch of A
imagination, an artificial calculation and, therefore, lease equalization is
an essential step in the accounting process to ensure that real income
from the transaction in the form of revenue receipts only is captured for
the purposes of income tax. Moreover, we do not find any express bar in
the IT Act which bars the bifurcation of the lease rental. This bifurcation
B
is analogous to the manner in which a bank would treat an EMI payment
made by the debtor on a loan advanced by the bank. The repayment of
principal would be a balance sheet item and not a revenue item. Only
the interest earned would be a revenue receipt chargeable to income
tax. Hence, we do not find any force in the contentions of the Revenue
that whole revenue from lease shall be subjected to tax under the IT C
Act.
15. Without a doubt, in a catena of cases, this court has discussed
the relevancy of the Guidance Note. While dealing with one of such
matters, this Court, in Commissioner of Income Tax-VII, New Delhi
vs. Punjab Stainless Steel Industries (2014) 15 SCC 129 held as under: D
“17. So as to be more accurate about the word “Turnover”, one
can either refer to dictionaries or to material which are published
by bodies of Accountants. The Institute of Chartered Accountants
of India (hereinafter referred to as the “ICAI”) has published
some material under the head “Guidance Note on Tax Audit under E
Section 44B of the Income Tax Act”. The said material has been
published so as to guide the members of the ICAI. In our opinion,
when a recognized body of Accountants, after due deliberation
and consideration publishes certain materials for its members, one
can rely upon the same….”
F
16. In the present case, the relevant Assessment Year is 1999-
2000. The main contention of the Revenue is that the Respondent cannot
be allowed to claim deduction regarding lease equalization charges since
as such there is no express provision regarding such deduction in the IT
Act. However, it is apt to note here that the Respondent can be charged
only on real income which can be calculated only after applying the G
prescribed method. The IT Act is silent on such deduction. For such
calculation, it is obvious that the Respondent has to take course of
Guidance Note prescribed by the ICAI if it is available. Only after
applying such method which is prescribed in the Guidance Note, the
H
606 SUPREME COURT REPORTS [2018] 5 S.C.R.
A Respondent can show fair and real income which is liable to tax under
the IT Act. Therefore, it is wrong to say that the Respondent claimed
deduction by virtue of Guidance Note rather it only applied the method
of bifurcation as prescribed by the expert team of ICAI. Further, a
conjoint reading of Section 145 of the IT Act read with Section 211 (un-
amended) of the Companies Act make it clear that the Respondent is
B
entitled to do such bifurcation and in our view there is no illegality in
such bifurcation as it is according to the principles of law. Moreover, the
rule of interpretation says that when internal aid is not available then for
the proper interpretation of the Statute, the court may take the help of
external aid. If a term is not defined in a Statute then its meaning can be
C taken as is prevalent in ordinary or commercial parlance. Hence, we do
not find any force in the contentions of the Revenue that the accounting
standards prescribed by the Guidance Note cannot be used to bifurcate
the lease rental to reach the real income for the purpose of tax under the
IT Act.
D 17. To sum up, we are of the view that the Respondent is entitled
for bifurcation of lease rental as per the accounting standards prescribed
by the ICAI. Moreover, there is no express bar in the IT Act regarding
the application of such accounting standards.
18. In view of above detailed discussion, we are not inclined to
E interfere in the impugned decision of the High Court. Accordingly, the
appeal is hereby dismissed leaving parties to bear their own cost. In
view of the above, other connected appeals are also disposed off
accordingly.
F Devika Gujral Appeals disposed of.
G
H
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