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 Religare Finvest Limited Vs. Deputy Commissioner Of Income Tax & Anr
  The Chartered Institute Of Taxation Vs. Institute Of Chartered Tax Advisers Of India Ltd.
 Dy. Commissioner of Income Tax, Central Circle-6, New Delhi. Vs. Sh. U.K. Bose, 1, Kapoorthala Complex, Aliganj, Lucknow (UP).
 M/s Radius Industries, S-57, F.I.E.E., Okhla Industrial Area, Phase-2, New Delhi Vs. Acit, Circle 28(1), New Delhi
 The Income Tax Officer, Ward-71(2), Room No.402, 4th Floor, D-Block, Civic Centre, New Delhi. Vs. Smt. Madhu Bala Gupta, D-5, Parwana Vihar, Sector-9, Rohini, New Delhi – 110 085.
 Late Manoj Kumar, Through Legal Heir Smt. Alka, RZ-C-1/76, Gali No.38, Mahavir Enclave-II, Palam, New Delhi–110059. Vs. The Income Tax Officer, Ward-44(5), E-2 Block, Civic Centre, New Delhi.
 The Income Tax Officer, Ward-58(2), New Delhi. Vs. Smt. Mahi Preet Kaur, B-24, Ganesh Nagar, Pandav Nagar, Delhi – 110 092.
 M/s. Gitanjali Promoters Pvt. Ltd., M-11, Middle Circle, Connaught Circus, New Delhi – 110 001. vs. The ACIT, Central Circle-23, E-2, ARA Centre, Jhandewalan Extension, New Delhi.
 The Bank of Tokyo-Mitsubishi UFJ Ltd., 5th Floor, Worldmark-2, Asset 8, Aerocity, NH-8, New Delhi-110037 Vs. Dy. C.I.T Circle-3(1)(1), International Taxation, New Delhi
 Satish Chand, S/o Sh. Baburam R/o Village Bali, Distt. Baghpat, Baghpat Vs. ITO Barauta
 Magan Behari Lal, S-89, Greater Kailash II, New Delhi-110048 Vs. DCIT, Circle-16(2), C.R. Building, I.P. Estate, New Delhi-110002

Religare Finvest Limited Vs. Deputy Commissioner Of Income Tax & Anr
September, 19th 2019

Referred Sections:
Section 142 (2A) of the Income Tax Act, 1961
Section 143(2) of the Act.
Sections 142 (2A) (2D), 142 (3) and 142 (4)

Referred Cases / Judgments:
Sahara India (Firm) v. CIT(2008) 14 SCC 151
Sahara India Financial Corporation Ltd. v. CIT (2017) 399 ITR 81 (DEL).
Supreme Court in Ram Krishna Dalmia v. Shri Justice S.R. Tendolkar, AIR 1958 SC 538:
Supreme Court in Subramaniam Swamy v. CBI, (2014) 8 SCC 682
Sahara India (Firm), Lucknow v. Commissioner of Income Tax, [2008] 300 ITR 403 (SC),
Swadeshi Cotton Mills Co. Ltd. v. C.I.T., [1988] 171 ITR 634 (All)
West Bengal State Co-operative Bank Ltd. v. Joint Commissioner of Income Tax, [2004] 267 ITR 345

$~59 & 60
*      IN THE HIGH COURT OF DELHI AT NEW DELHI
                                              Date of decision: 28th August, 2019

+      W.P.(C) 9358/2019
RELIGARE FINVEST LIMITED                                   ..... Petitioner
                                Through:   Mr. Ajay Vohra, Senior Advocate
                                           with Mr. Rohit Jain, Ms. Kavita Jha
                                           and Mr. VaibhavKulkarni, Advocates.

                       versus

DEPUTY COMMISSIONER OF INCOME TAX & ANR...... Respondent
                 Through: Mr. Raghvendra Singh, Senior
                          Standing Counsel with Mr. Vipul
                          Agrawal, Junior Standing Counsel.

+      W.P.(C) 9359/2019
RELIGARE ENTERPRISES LIMITED                              ..... Petitioner
                                Through:   Mr. Ajay Vohra, Senior Advocate,
                                           Mr. Rohit Jain, Ms. Kavita Jha and
                                           Mr. Vaibhav Kulkarni, Advocates.

                       versus

DEPUTY COMMISSIONER OF INCOME TAX & ANR...... Respondents
                 Through: Mr. Raghvendra Singh, Senior
                          Standing Counsel with Mr. Vipul
                          Agrawal, Junior Standing Counsel.


CORAM:
HON'BLE MR. JUSTICE VIPIN SANGHI
HON'BLE MR. JUSTICE SANJEEV NARULA




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                                Page 1 of 28
SANJEEV NARULA, J. (Oral) :

C.M. No 38598/2019 in W.P.(C) 9358/2019 &
C.M. No 38600/2019 in W.P.(C) 9359/2019

1. Exemption allowed, subject to all just exceptions.
2. The applications stands disposed of.


W.P.(C) 9358/2019 & CM APPL. 38597/2019 &
W.P.(C) 9359/2019 & CM APPL. 38599/2019

3. Both the present petitions under Article 226 of the Constitution of India
challenge the respective orders, both dated 06.08.2019, passed by Deputy
Commissioner of Income Tax, Circle 21 (1), C.R. Building, I.P. Estate, New
Delhi directing the Petitioners to have their books of account for the
assessment year 2016-17 audited by the Special Auditor under Section 142
(2A) of the Income Tax Act, 1961 (hereinafter referred to as the ,,Act).




Brief Facts
4. The facts and grounds urged in both the petition are more or less similar
and furthermore since identical arguments have been advanced, the same are
being decided by a common judgment. However, facts narrated in WP (C)
No. 9359/2019 are being noted and discussed for the purpose of deciding the
petitions.


5. The Petitioner contends that it is engaged in the business of lending,




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                           Page 2 of 28
investment, financial advisory services and distribution of third-party
financial products and has been consistently following the same method of
accounting for the purpose of maintaining its books of account and filing its
tax return. For assessment year 2016-17, the year under consideration, the
Petitioner originally e-filed its return of income declaring total income of
Rs. 44,64,06,770/-. The return of income was revised declaring same total
income. The case of the Petitioner was selected for scrutiny through CASS
and notice was issued under section 143(2) of the Act. During assessment
proceedings, Respondent No.1 called for various information, details and
data, which were duly furnished by the Petitioner from time to time. The
Petitioner filed, before the Revenue, a copy of the order dated 14.03.2019
passed by Securities & Exchange Board of India (,,SEBI). In the said letter,
the Petitioner explained that SEBI, vide order dated 14.03.2019, directed the
Petitioner and M/s. Religare Finvest Ltd. (,,RFL), subsidiary of the
Petitioner, to initiate steps to recall all the loans diverted to the companies
associated with the former promoters.


6. Petitioner further represented that the new professional management of
the Petitioner is taking all steps to recall the loan and that the transactions
referred in the SEBI order, in any case, had no effect on the taxable income
of the Petitioner.


7. A show-cause notice dated 30.05.2019 was issued by Respondent No.1
requiring the Petitioner to furnish certain details/information by 06.06.2019.
In the said notice, Respondent No.1 referred to forensic audit report
furnished by SEBI and its order dated 14.03.2019 alleging diversion/




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                            Page 3 of 28
siphoning of funds of the Petitioner to the companies related to its erstwhile
promoters. The Petitioner was directed to give an explanation and to show-
cause why books of account may not be rejected.


8. In the meanwhile, despite Petitioner furnishing the details as directed, a
notice dated 13.06.2019 was issued by Respondent No. 1 requiring it to
show-cause as to why books of accounts of the Petitioner may not be
referred for special audit under section 142 (2A) of the Act, considering the
complexity and volume of the accounts and the specialized nature of the
business activity of the Petitioner. In the said show-cause notice Respondent
No. 1 primarily referred to and reproduced the contents of the notice dated
30.05.2019, and stated that, "Due to complexity of transactions and
voluminous books of account and details, specialized nature of business
activity", the accounts of the Petitioner are proposed to be referred for
special audit under section 142(2A) of the Act. Petitioner was directed to
furnish its response within 4 days, i.e. by 17.06.2019.



9. In response to the aforesaid notice, the Petitioner gave an elaborate reply
dated 17.06.2019, rebutting the allegations and inter alia contending that
reference for special audit was unwarranted. Petitioner referred to several
decisions dealing with the subject, and in particular the judgment of the
Supreme Court in Sahara India (Firm) v. CIT(2008) 14 SCC 151 and also
the decision of this Court in Sahara India Financial Corporation Ltd.
v. CIT (2017) 399 ITR 81 (DEL). It was urged that considering that
there was no change in the nature of business of the Petitioner, its




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                           Page 4 of 28
business could not be categorized as "specialized nature of business
activities". Petitioner had undertaken transactions by way of giving loans
and advances in the normal course of business of financing and each and
every transaction is fully and appropriately recorded in the books of
accounts and this is apparent on the face of the financial statement.
Petitioner controverted that it has several subsidiaries, and explained that all
the transactions entered into by the Petitioner with its sole subsidiary viz
Religare Housing Development Finance Corporation are duly disclosed in
the related party transaction schedule of audited financial statement.
Regarding SEBI order dated 14.03.2019, it was argued that vide an earlier
letter dated 06.05.2019 filed before principal CIT, Petitioner had elaborately
explained the background of the aforesaid order, and that there was no
revenue loss to the Income Tax Department.              Thus, essentially the
contention of the Petitioner was that there was no complexity in the books of
account which would warrant the Respondent No. 1 to direct special audit.


10. Respondent No. 1 considered the reply furnished by the Petitioner and
after seeking approval of the Principal Commissioner of Income Tax, passed
the order dated 06.08.2019 and directed M/s Das Gupta and Associates,
Chartered Accountants to audit the accounts of the Petitioner as per the
terms of reference within a period of ninety days.


WP (C) NO. 9358/2019
11. In the present case, the Petitioner, Religare Finvest Limited (RFL) is a
subsidiary of the Petitioner in WP(C) No. 9359/2019. As the challenge is to
a similar order dated 06.08.2019 passed by the Deputy Commissioner of




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                             Page 5 of 28
Income Tax, after seeking approval of Principal Commissioner of Income
Tax, directing M/s Das Gupta and Associates, Chartered Accountants to
audit the accounts of the Petitioner. The grounds challenging the impugned
order are identical to those which have been raised in W.P.(C) 9359/2019
and therefore our findings and reasons are applicable to both the parties.


12. However, it may be noted that the return of income e-filed by the
Petitioner in W.P. (C) No. 9358/2019, Religare Finvest Limited (RFL),
declared a total income of Rs.506,61,50,010/- . The return of income was
revised declaring total income of Rs. 504,21,26,280/-.


Contentions of the Petitioner
13. The Petitioner has impugned the aforesaid order, alleging that there is a
gross violation of the principles of natural justice and the order has been
passed without affording the Petitioner any opportunity of being heard. Mr.
Ajay Vohra, learned Senior counsel for the Petitioners argued that the order
under Section 141 (2A) leads to serious civil consequences and such an
order cannot be passed as a matter of routine, but only if the circumstances
so warrant. Petitioner was not afforded with a reasonable opportunity of
being heard prior to directing special audit and, thus, the order is vitiated on
account of violation of principles of natural justice. The order suffers from
the vice of lack of fulfilment of jurisdictional conditions for directing special
audit. He further submitted that Section 142 (2A) was amended pursuant to
Finance Act, 2013 with effect from 01.06.2013. Prior to the amendment,
special audit under the aforesaid provision could have been directed only in
cases where the accounts of the assessee were "complex" in nature, and




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                             Page 6 of 28
having regard to the interests of Revenue. After the amendment of the said
provision, the scope, of the provision has been expanded. However, the
exercise of the power under the amended provision has to be guarded and
exercised with circumspection.          The expanded, enlarged provisions of
Section 142 (2A) would still require, as a condition precedent, the Assessing
Officer to demonstrate the complexity of the accounts of the assessee, which
an ordinary prudent person, reasonably informed about accounts and law, is
not in a position to comprehend. The provision of Section 142 (2A) cannot
be construed to mean that in every case where there is a large volume of
accounts and multiplicity of transactions, the Assessing Officer can direct
the conduct of a special audit under the aforesaid provision.        Such an
interpretation would be highly irrational and illogical in as much as, in case
of every assessee having substantial turnover and reported taxable income, it
would become possible to order conduct of a special audit in routine merely
on the ground that the volume of accounts and multiplicity of transactions is
large. The nature of business of the Petitioner which involves dealing with
lakhs of people, would necessarily result into a high turnover, which is more
than Rs. 2000 crores. This does not mean that in case of an assessee having
turnover in excess of Rs. 2000 crores, special audit has to be directed as a
matter of rule or mechanically. He relied upon the decision of the Supreme
Court in the case of Sahara India (Firm) (supra) to contend that the
impugned order is wholly without jurisdiction, illegal and bad in law. Mr.
Vohra rebutted all the comments/findings of Respondent No. 1 in the
impugned order, and stressed that Respondent No. 1 has not made any
attempt to understand the accounts of the Petitioner, and has proceeded with
a premeditated mind to make a reference for special audit. Lastly, he argued




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                           Page 7 of 28
that the order of reference is not appropriate and has been passed on
surmises and conjectures and by virtue of the said order, the AO bypassed
the burden of undertaking the assessment to the special auditor who has
been given the responsibility to verify the books of accounts of the
Petitioner, to complete the assessment.


14. Learned counsel for the Revenue on the other hand, relied upon the
judgment of this Court in AT &T Communication Services India (P.) Ltd.
Commissioner of Income Tax and Anr. [2014] 362 ITR 1997 (DELHI) to
contend that under Article 226, the Court ordinarily does not interfere with
the order passed by the Assessing Officer under section 142(2A) of the Act.
He urged that the order suffers from no infirmity and the AO has duly
applied his mind and has after due consideration of the facts, in his
discretion held that he requires the assistance of the special auditor.


Analysis and Findings
15. We have given our thoughtful consideration to the contentions raised by
the parties. Section 142 (2A) of the Act provides that the Assessing Officer,
having regard to the nature and complexity of the accounts of the assessee,
volume of the accounts, doubts about the correctness of the accounts,
multiplicity of the transactions in the accounts or specialized nature of the
business activity of the assessee and the interests of the revenue, may at any
stage of the proceedings before him, direct the assessee to get the accounts
audited by special auditor after obtaining previous approval of the Chief
Commissioner or Principal Commissioner. The plain language of the
provision indicates that in order to make reference for special audit under




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                              Page 8 of 28
Section 142 (2A) of the Act, certain essential jurisdictional conditions are
required to be satisfied and in absence thereof, the direction for special audit
may not be warranted. This provision was amended by the Finance Act,
2013 whereby the words "volume of the accounts, doubts about the
correctness of the accounts, multiplicity of transactions in the accounts or
specialized nature of business activities of theAssessee" have been inserted
after the expression "the nature and complexity of the accounts", w.e.f.
1.6.2013. Prior to the amendment, special audit under Section 142(2A) of
the Act could have been directed only in case the accounts of the Assessee
were "complex" in nature and having regard to the interests of the revenue.
The reason behind the amendment can be inferred from the Memorandum
Explaining provisions in the Finance Bill, 2013, which reads as follows:
      "Direction for special audit under sub-section (2A) of section 142
      The existing provisions contained in sub-section (2A) of section
      142 of the Income-tax Act, inter alia, provide that if at any stage
      of the proceeding, the Assessing Officer having regard to the
      nature and complexity of the accounts of the assessee and the
      interests of the revenue, is of the opinion that it is necessary so to
      do, he may, with the approval of the Chief Commissioner or
      Commissioner, direct the assessee to get his accounts audited by
      an accountant and to furnish a report of such audit.

      The expression "nature and complexity of the accounts" has
      been interpreted in a very restrictive manner by various
      courts.

      It is, therefore, proposed to amend the aforesaid subsection
      so as to provide that if at any stage of the proceedings before
      him, the Assessing Officer, having regard the nature and
      complexity of the accounts, volume of the accounts, doubts
      about the correctness of the accounts, multiplicity of
      transactions in the accounts or specialized nature of business




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                               Page 9 of 28
      activity of the assessee, and the interests of the revenue, is of
      the opinion that it is necessary so to do, he may, with the
      previous approval of the Chief Commissioner of the
      Commissioner, direct the assessee to get his accounts audited
      by an accountant and to furnish a report of such audit."

16. Mr. Vohra has argued that notwithstanding the amendment, the said
provision must be read in proper context and perspective. He argued that
the said expression would apply in situations where the volume of the
accounts or the multiplicity of transactions in the accounts are
disproportionate to the size, volume and the reportable taxable income of the
assessee.


17. There cannot be any dispute regarding the proposition advanced by Mr.
Vohra that Section 142 (2A) of the Act cannot be resorted by the Assessing
Officer on his mere ipse dixit. The expanded/enlarged provisions of Section
142 (2A) of the Act would still require the fulfilment of the conditions
precedent for the Assessing Officer to exercise his jurisdiction for ordering a
special audit .While upholding the constitutional validity of the amendment
made by the Finance Act, 2013, this Court in Sahara India Finance
Corporation Ltd. v. CIT (supra), has held that even after the amendment, it
is imperative for the Assessing Officer to make a genuine attempt to
understand the accounts before making a reference under the said section.
The relevant passage of the said decision is para 36, wherein the principles
emerging from the decision of the Supreme Court in the case of Sahara
India (Firm) v. CIT(supra)have been discussed. Further the applicability of
the ratio of the Supreme Court decisions, even to the amended Section 142
(2A) of the Act is evident from the following paras:









W.P.(C) 9358/2019 & W.P.(C) 9359/2019                            Page 10 of 28
      "28. The rationale for the amendment, therefore, is that the
      erstwhile expression "nature and complexity of the accounts" had
      been interpreted in a restrictive manner by courts. The petitioner
      submits that such an amendment runs afoul of the guarantee
      under Article 14 of the Constitution. Before dealing with the
      constitutionality of the aforesaid amendment, it would be fitting
      to recollect the basic principles that must be kept in mind by the
      Courts while dealing with the challenge to the constitutionality of
      a legislative enactment. These principles were succinctly stated
      by the Supreme Court in Ram Krishna Dalmia v. Shri Justice
      S.R. Tendolkar, AIR 1958 SC 538:
         "14. The principle enunciated above has been
         consistently adopted and applied in subsequent cases.
         The decisions of this Court further establish-
         (a) that a law may be constitutional even though it relates
         to a single individual if, on account of some special
         circumstances or reasons applicable to him and not
         applicable to others, that single individual may be treated
         as a class by himself;
         (b) that there is always a presumption in favour of the
         constitutionality of an enactment and the burden is upon
         him who attacks it to show that there has been a clear
         transgression of the constitutional principles;
         (c) that it must be presumed that the legislature
         understands and correctly appreciates the need of its own
         people, that its laws are directed to problems made
         manifest by experience and that its discriminations are
         based on adequate grounds;
         (d) that the legislature is free to recognise degrees of
         harm and may confine its restrictions to those cases
         where the need is deemed to be the clearest;
         (e) that in order to sustain the presumption of
         constitutionality the court may take into consideration
         matters of common knowledge, matters of common
         report, the history of the times and may assume every
         state of facts which can be conceived existing at the time
         of legislation; and
         (f) that while good faith and knowledge of the existing




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                            Page 11 of 28
         conditions on the part of a legislature are to be
         presumed, if there is nothing on the face of the law or the
         surrounding circumstances brought to the notice of the
         court on which the classification may reasonably be
         regarded as based, the presumption of constitutionality
         cannot be carried to the extent of always holding that
         there must be some undisclosed and unknown reasons for
         subjecting certain individuals or corporations to hostile
         or discriminating legislation.
         15. The above principles will have to be constantly borne
         in mind by the court when it is called upon to adjudge the
         constitutionality of any particular law attacked as
         discriminatory and violative of the equal protection of the
         laws."

      29. The above principles have been consistently followed by the
      courts in India and the law in relation to challenge on the
      constitutionality of an enactment on the touchstone of Article 14
      was reiterated by the Supreme Court in Subramaniam
      Swamy v. CBI, (2014) 8 SCC 682 in the following terms:
        "Where there is challenge to the constitutional validity of
        a law enacted by the legislature, the Court must keep in
        view that there is always a presumption of
        constitutionality of an enactment, and a clear
        transgression of constitutional principles must be shown.
        The fundamental nature and importance of the legislative
        process needs to be recognised by the Court and due
        regard and deference must be accorded to the legislative
        process. Where the legislation is sought to be challenged
        as being unconstitutional and violative of Article 14 of
        the Constitution, the Court must remind itself to the
        principles relating to the applicability of Article 14 in
        relation to invalidation of legislation. The two dimensions
        of Article 14 in its application to legislation and
        rendering legislation invalid are now well recognised and
        these are: (i) discrimination, based on an impermissible
        or invalid classification, and (ii) excessive delegation of
        powers; conferment of uncanalised and unguided powers




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                            Page 12 of 28
         on the executive, whether in the form of delegated
         legislation or by way of conferment of authority to pass
         administrative orders-if such conferment is without any
         guidance, control or checks, it is violative of Article 14 of
         the Constitution. The Court also needs to be mindful that
         a legislation does not become unconstitutional merely
         because there is another view or because another method
         may be considered to be as good or even more effective,
         like any issue of social, or even economic policy. It is well
         settled that the courts do not substitute their views on
         what the policy is."

      xxxxxxxxx

      34. The task that this Court is, therefore, faced with is to
      determine whether the grounds added by amendment to Section
      142(2A) of the Act, are of such nature that they violate Article 14
      of the Constitution. In this regard, the mere possibility that the
      AO may abuse the discretion that the provision vests in him
      would be insufficient to declare the provision as unconstitutional.
      The       Supreme        Court      in Sahara     India      (Firm),
      Lucknow v. Commissioner of Income Tax, [2008] 300 ITR 403
      (SC), had the occasion to interpret Section 142(2A) of the Act, as
      it stood prior to the amendments in question. The Court was
      faced with the question as to whether Section 142(2A) required
      giving the assessee a pre-decisional hearing before proceeding to
      order a special audit under the provision. The Court noted:
         "A bare perusal of the provisions of Sub -section (2A) of
         the Act would show that the opinion of the Assessing
         Officer that it is necessary to get the accounts of assessee
         audited by an Accountant has to be formed only by
         having regard to: (i) the nature and complexity of the
         accounts of the assessee; and (ii) the interests of the
         revenue. The word "and" signifies conjunction and not
         disjunction. In other words, the twin conditions of
         "nature and complexity of the accounts" and "the
         interests of the revenue" are the prerequisites for
         exercise of power under Section 142(2A) of the Act.




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                              Page 13 of 28
         Undoubtedly, the object behind enacting the said
         provision is to assist the Assessing Officer in framing a
         correct and proper assessment based on the accounts
         maintained by the assessee and when he finds the
         accounts of the assessee to be complex, in order to
         protect the interests of the revenue, recourse to the said
         provision can be had. The word "complexity" used in
         Section 142(2A) is not defined or explained in the Act. As
         observed        in Swadeshi       Cotton     Mills      Co.
         Ltd. v. C.I.T., [1988] 171 ITR 634 (All) it is a nebulous
         word. Its dictionary meaning is: "The state or quality of
         being intricate or complex or that is difficult to
         understand. However, all that is difficult to understand
         should not be regarded as complex. What is complex to
         one may be simple to another. It depends upon one's level
         of understanding or comprehension. Sometimes, what
         appears to be complex on the face of it, may not be really
         so if one tries to understand it carefully." Thus, before
         dubbing the accounts to be complex or difficult to
         understand, there has to be a genuine and honest attempt
         on the part of the Assessing Officer to understand
         accounts maintained by the assessee; appreciate the
         entries made therein and in the event of any doubt, seek
         explanation from the assessee. But opinion required to be
         formed by the Assessing Officer for exercise of power
         under the said provision must be based on objective
         criteria and not on the basis of subjective satisfaction.
         There is no gainsaying that recourse to the said provision
         cannot be had by the Assessing Officer merely to shift his
         responsibility of scrutinizing the accounts of an assessee
         and pass on the buck to the special auditor. Similarly, the
         requirement of previous approval of the Chief
         Commissioner or the Commissioner in terms of the said
         provision being an inbuilt protection against any
         arbitrary or unjust exercise of power by the Assessing
         Officer, casts a very heavy duty on the said high ranking
         authority to see to it that the requirement of the previous
         approval, envisaged in the Section is not turned into an




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                            Page 14 of 28
         empty ritual. Needless to emphasise that before granting
         approval, the Chief Commissioner or the Commissioner,
         as the case may be, must have before him the material on
         the basis whereof an opinion in this behalf has been
         formed by the Assessing Officer. The approval must
         reflect the application of mind to the facts of the case."

      35. On the question of whether Section 142(2A) involves giving
      a predecisional hearing to the assessee, the Court held:
      "The upshot of the entire discussion is that the exercise of
      power under Section 142(2A) of the Act leads to serious
      civil consequences and, therefore, even in the absence of
      express provision for affording an opportunity of pre-
      decisional hearing to an assessee and in the absence of any
      express provision in Section 142(2A) barring the giving of
      reasonable opportunity to an assessee, the requirement of
      observance of principles of natural justice is to be read into
      the said provision."

      36. Thus, what emerges from the Sahara (supra) decision of the
      Supreme Court in relation to Section 142(2A), can be
      summarized as under:
      (i) The Assessing Officer must make a genuine and honest
      attempt to understand the accounts maintained by the assessee.
      (ii) The opinion required to be formed by the Assessing Officer
      under Section 142(2A) must be based on objective criteria and
      not merely subjective satisfaction. The powers under the
      provision cannot be used by the Assessing Officer merely to shift
      his responsibility of scrutinizing the accounts to the special
      auditor.
      (iii) The requirement of previous approval of the Chief
      Commissioner or Commissioner, casts a heavy duty on these
      authorities to ensure that this requirement is not reduced to an
      empty formality. Before granting the approval, the Commissioner
      or the Chief Commissioner, must have before him the materials
      on the basis of which the opinion has been formed by the
      Assessing Officer. The approval granted by the Commissioner or
      the Chief Commissioner must reflect application of mind to the




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                           Page 15 of 28
      facts of the case. This requirement was elaborated by the Calcutta
      High Court in West Bengal State Co-operative Bank Ltd. v. Joint
      Commissioner of Income Tax, [2004] 267 ITR 345 (Cal), where
      it noted that-
         "The Commissioner of Income Tax should not give any
         approval mechanically and if he finds that there is no
         examination of the books of account by the Assessing
         Officer before sending the proposal, he will not certainly
         give any approval. Under this section, the Commissioner
         of Income Tax does not exercise the jurisdiction of the
         appellate authority rather the approving authority.
         Approval means and connotes supporting and accepting
         of an act and conduct done by another person. Therefore,
         it would be his duty to examine on receipt of his proposal,
         whether the Assessing Officer has correctly done it or
         not, if he finds that this requirement has not been fulfilled
         then he must not approve of the same."
      (iv) In accordance with the principles of natural justice, the
      assessee must be given the opportunity of a pre-decisional
      hearing before action is taken under Section 142(2A).

      37. While this decision of the Supreme Court was prior to the
      amendments inserted by the Finance Act, 2013, this Court sees
      no reason as to why these holdings of the Supreme Court
      in Sahara (supra) would not be applicable to the amended
      Section 142(2A). The fact that the AO's determination under this
      provision must be based on objective material and not subjective
      satisfaction, that he must make an honest attempt at
      understanding the accounts of the assessee, that the grant of
      approval by the higher authority must not be mechanical, that
      principles of natural justice must be followed by giving the
      assessee a pre-decisional hearing, would all be equally applicable
      even under the amended Section 142(2A). It would still be
      impermissible for the AO to shift the responsibility of auditing
      the accounts mechanically to the special auditor. In these
      circumstances, we fail to understand the petitioner's contention as
      to how the amendments would in effect nullify these procedural
      safeguards that the Supreme Court has read into Section




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                            Page 16 of 28
      142(2A)."
                                                   (Emphasis supplied)
18. While there can be no quarrel with the proportion that the Assessing
Officer while exercising jurisdiction under Section 142 of the Act should
ensure compliance with the aforesaid view of this Court in Sahara India
Finance Corporation Ltd. (supra), we are, however, not convinced with the
submission of Mr. Vohra that notwithstanding the amendment, the scope of
the said provision should be limited and restricted to only those categories of
cases, where the volume of account, or the multiplicity of transactions are
disproportionate to the size and volume of business and the reported taxable
income of the assessee. Since the legislative intent while amending Section
142 was to expand and enlarge the scope of the jurisdiction of the
Competent Authority to order special audit, by laying down the guideline for
exercise of the said jurisdiction, it cannot be interpreted to give it a
restrictive meaning. If the legislature has added new words in the grounds
for ordering a special audit under section 142(2A), it would be contrary to
all rules of construction to ignore the impact of the newly added words and
to so construe the definition as if the newly added words were either not
there or were intended to be otiose and redundant. Such an interpretation
would neutralize the effect of the amendment and run counter to the
legislative intent. From a bare reading of the amended provision, we are
unable to discern a restrictive scope, as sought to be interpreted by Mr.
Vohra. The AO can resort to the aforesaid provision under any of the
circumstances, mentioned in the section. If the subjective satisfaction of the
Assessing Officer is based on objective assessment, for any of the reasons
specified in the amended provision, the court would not ordinarily interfere




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                            Page 17 of 28
with the exercise of the discretionary power vested with the AO under the
said provision. Of course, the expanded provisions are not without fetters
and safeguards. The power under Section 142 (2A) of the Act cannot be
exercised lightly, and the Assessing Officer must exercise his discretion in a
reasonable manner by taking into account all relevant and germane aspects.
The exercise of the power would be subject to the guiding principles laid
down by the Supreme Court in Sahara India (Firm) (supra), as notice by
this Court in Sahara India Finance Corporation Ltd.(supra).


19. Now lets examine the reasons assigned by Respondent No. 1 in the
impugned order dated 06.018.2019 directing special audit. While testing the
reasoning on the touchstone of the principles enunciated by the Supreme
Court in Sahara India (Firm) (supra), we would like to underscore that
while exercising jurisdiction under Article 226 of the Constitution of India,
the Court does not be sit in appeal over the order passed by the Assessing
Officer.     The subjective satisfaction is a subject matter which falls
exclusively within the domain of the Assessing Officer. In Article 226, we
would not like to tread or invade into the jurisdiction of the AO. As long as
the exercise of the jurisdiction is based on cogent reasons, Court would
certainly have the jurisdiction to examine whether the discretion to refer the
account for special audit was exercised objectively, or not. However whether
the material produced before the AO was sufficient for him to conclude
"complexity " would essentially remain a matter falling in his discretion. In
fact, the view expressed by this Court, in AT &T Communication Services
India (P.) Ltd. (supra), lays down the scope of interference of the Court in
such matters in the following words:




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                           Page 18 of 28
      "16. The question whether the accounts and the related
      documents and records available with the A.O. present
      complexity is essentially to be decided by the A.O. and in this
      area the power of the court to intrude should necessarily be
      used sparingly. It is the A.O. who has to complete the
      assessment. It is he who has to understand and appreciate the
      accounts. If he finds that the accounts are complex, the court
      normally will not interfere under Article 226. The power of the
      court to control the discretion of the A.O. in this field is limited
      only to examine whether his discretion to refer the accounts for
      special audit was exercised objectively, as far as the accounts,
      records, documents and other material present before the A.O.
      would permit. There must be valid material before the A.O. from
      which he apprehends that there is complexity. As to what
      material would make the accounts complex is essentially for the
      A.O. to determine and unless his decision can be attacked on the
      ground of perversity or absolute arbitrariness or mala fide, it
      should not be interfered with. In the present case we are satisfied
      that the accounts including the documents, records and other
      material before the A.O. did make the issues for his decision
      complex requiring a special audit. We are accordingly not
      inclined to accept the contention of the assessee to the contrary."
                                                      (Emphasis supplied)


20. Though the above decision was rendered in the context of the
unamended provisions, views expressed concerning the scope of jurisdiction
of the Court under Article 226 are still relevant and would be applicable. In
view of the limited and guarded scope of judicial review, we now proceed to
evaluate the impugned order. The Assessing Officer has taken a view that
there is complexity in the accounts of the assessee. He is also of the view
that the interests of the revenue are adversely affected. The relevant portion
of the impugned order reads as under:
      "15. Anomalies and complexities noted in the books of









W.P.(C) 9358/2019 & W.P.(C) 9359/2019                            Page 19 of 28
      accounts of the assessee:
      During the course of assessment proceedings various anomalies
      and complexities were noted in the books of accounts of the
      Assessee company. These were communicated to assessee
      company vide show cause notice dated 30.05.2019 and
      subsequently vide show cause notice issued under section
      142(2A) of the Act. The reply of the assessee company filed on
      06.06.2019, 12.06.2019, 17.06.2019 and 28.06.2019, in this
      regard, have been considered and the same has been disposed of
      issue wise as under:
      a. The assessee company is a Non-banking Finance Company
      (NBFC) engaged in the business of financing. The assessee
      borrowed loans from Various Banks, Financial Institutions and
      others on which interest was paid. The said loans were given to
      various parties and interest received from them was declared as
      income. Total loans of Rs. 682 Crores borrowed by the assessee
      company and total amount of Rs. 232 Crores lent by the assessee
      were outstanding as on 31/03/2016. The assessee declared
      interest income of Rs. 125.40 Crores during the year and has
      claimed interest expense of Rs. 110 Crores. The assessee has also
      claimed professional / litigation expenses of Rs. 3,53,45,032/-.
      (a.i) Further, an amount of Rs. 432.92 Crores was invested by the
      company in its subsidiaries / associated concerns / group
      companies and an amount of Rs. 218.84 Crores was given as
      loans and advances to them. An amount of Rs. 24,17,69,927/- has
      been shared as expenses with its associated concerns during the
      year without any stated reasons/ basis. Thus, the transactions
      with the associated concerns / related parties involved huge
      amounts.
      (a.ii) Enquiries were conducted and action taken against the
      assessee company by various Government agencies like
      Enforcement Directorate (ED), Serious Fraud Investigation
      (SFIO), Delhi Police (EOW) etc. In the said enquiries, it comes
      out that the assessee has diverted the funds for the benefit of
      promoter and promoter group companies and was involved in
      siphoning of funds borrowed by it by way of advancing money or
      paying expenses paid to its associated concerns or making
      investment in them in the form of shares.




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                          Page 20 of 28
      (a.iii) The assessee was specifically raised query regarding the
      fact of misappropriation and siphoning of funds vide notice dated
      30/05/2019 vide point no. 13.In this connection, report of the
      forensic audit of the assessee company got conducted by the
      SEBI which bears testimony to the said diversion/siphoning of
      funds, was also confronted to the assessee company.

      (a.iv) The assessee categorically denied that some of the
      transactions mentioned therein were related to the assessee or
      entered into by it and further stated that the observations made by
      SEBI and Forensic Auditor in respect of transaction were not
      applicable. However, no such evidence was placed on record to
      show that these transactions were not entered into by the assessee
      or the same were not related to the assessee. Thus, an in-depth
      verification of the books of account is required to ascertain and
      establish the fact about these transactions.
      b. The assessee company has recorded huge losses on account of
      investment made in the subsidiary / associated companies/
      partnership firms etc. Capital gain / loss of Rs. 371,47,42,141/-
      has been claimed on sale of such investments during the year.
      The assessee was raised specific query regarding the said claim
      vide point no. 1 of the notice dated 30/05/2019. In reply the
      assessee company placed voluminous information in the form of
      agreement; balance sheets etc. on record which needs in depth
      verification for allowability of the said claim. The said
      information runs into 9 bulky volumes of more than 1000 pages.
      Justification regarding the investment into the subsidiary /
      associated companies/ partnership firms and resultant gain/loss
      has also not been provided.
      c. The assessee has made provision of Rs. 279.25 crores for
      diminution in value of investment made in subsidiary company
      during the year. Each year such provisions are made for
      diminution in the value of shares of subsidiary company which
      creates a suspicion as to how the value of investment in
      subsidiaries can diminish at such a level. Despite being
      confronted on this issue no satisfactory reply with the help of
      relevant supporting evidencescould be furnished by the assessee.
      In fact the reply needs indepth




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                            Page 21 of 28
      backward integration and verification of the reasons/business
      expediency/sources having revenue implication that ultimately
      lead to such diminution.
      d. The assessee claimed legal and professional fees of Rs.
      3,53,45,032/- in its profit and loss account. The assessee was
      asked to substantiate the same vide point no. 3 of notice dated
      30/05/2019. The assessee submitted copies of the invoices / bills
      of the said expenses. On perusal of the bills, it was observed that
      the same pertained to the litigation expenses related to various
      cases against company, Managing director, key personnel etc.
      Since a number of criminal cases have been launched against the
      company and its key personnel, so each and every bill along with
      the litigation status of each case needed in depth verification to
      examine the allowability of such expenses have been factually
      incurred solely & exclusively for the purpose of business of the
      assessee. The assessee company though queried on the issue
      calling for specific details and supporting evidence, did not file
      the complete details as required. Thus, prima facie it can not be
      denied that the personal expenses of the directors have been
      claimed as legal expenses of the assessee company.
      e. There is multiplicity of transactions of borrowing, lending and
      investing with same parties or same nature of transactions with
      various parties. As already stated, that the assessee has borrowed
      funds of Rs. 682 crores and lent funds of Rs. 232 crore during the
      year under consideration. The assessee has lent money to various
      parties from whom interest has been earned. The funds have been
      borrowed and lent on different terms and conditions. However,
      the assessee has only provided lists in support without going into
      the detail as to how the revenue has been recognised on all the
      transactions of such nature and also amongst the parties to whom
      the money has been lent or obtained including the associated and
      group concerns.
      f. Further, this is an NBFC company which is governed by RBI
      and is engaged in specialized nature of business activity and not a
      regular business involving manufacturing or trading. Various
      rules and regulations are applicable on such entities. This NBFC
      has undertaken transactions with its associated companies as a
      chain or series of transactions. The money has been rotated




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                            Page 22 of 28
      through various companies through layering. Further, there are
      allegations of misappropriation of funds. Thus, the accounts are
      not only voluminous but are complex and need in depth
      verification for ascertaining the actual nature of transactions.
      (f.i) The assessee was asked to produce books of account.
      However, the assessee stated in para 11.1 of its submissions as
      under:
      "With reference to the same, it is submitted that the assessee has
      already submitted ledger accounts, party-wise details and
      relevant information with respect to the points raised vide the
      subject mentioned SCN. The relevant extracts of the documents
      relating to the anomalies as mentioned in the SEBI report have
      been enclosed as per the reply in the preceding paras. However,
      of your goodself required any other information in respect of
      books of accounts, then please let us know specific requirement,
      the assessee shall submit the same...................."
      (f.ii) This shows that the assessee is reluctant to produce the
      books of account, as it will reveal the true nature of the
      transactions undertaken by the assessee. It must be appreciated
      that ledgers of particular expenses helps to understand the nature
      of the said expense but the books of account need to be verified
      in detail to understand the overall scenario of the business of the
      assessee and transactions undertaken by it. Non-production of the
      books of account further strengthens the view about the
      correctness of the same.
      g. As of now, enquiries were conducted and action was taken
      against the assessee company by various Government agencies
      like Enforcement Directorate (ED), Special Fraud Investigation
      (SFIO), Delhi Police (EOW) etc. In the said enquiries, it comes
      out that the assessee has diverted the funds for the benefit of
      promoter and promoter group companies and was involved in
      siphoning of funds borrowed by it, by way of advancing money
      or paying expenses paid to its associated concerns or making
      investment in them in the form of shares. In fact the Promoter
      director vide his complaint to Delhi Police(EOW) has himself
      alleged that accused(s) as mentioned in the complaint have
      carried out and orchestrated serious financial fraud in two
      companies namely Religare Enterprise Limited and




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                            Page 23 of 28
      ReligareFinvest Limited in addition to RHC Holdings (P) Ltd
      and such fraud has been undertaken by the accused(s) in a pre-
      planned manner through various dubious transaction(s). This fact
      has also been amply illustrated, as already mentioned, in the
      Forensic audit report of the SEBI dated 12.12.2018 shared with
      the department and also confronted to the assessee company by
      the Assessing officer.
      (g.i) The assessee has no satisfactory answer to the said report
      and issues related to it. It is pertinent to mention that this is when
      the assessee company itself in a series of complaints/petitions
      before various regulatory authorities including EOW wing of
      Delhi Police have since been alleging that diversion of funds has
      been made and thus been claiming its retrieval through suitable
      Statutory order from the competent authorities. Thus, the fact of
      diversion/ siphoning of finds remaining un-refuted, stands as
      established and revenue implication involved in it can only be
      investigated through a special audit by a technical expert like a
      special auditor.
      h. Further it is held by judicial authorities all over the country
      that assessing officer is duty bound to determine the correct
      income/loss of each assessment year of an assessee. The purpose
      of direction for special audit is to ensure that a correct assessment
      order is passed so that revenue is not deprived of its dues. The
      direction to the Assessee for compulsory audit of accounts u/s
      142(2A) of the Income Tax Act does not affect the Assessees
      right especially in view of the fact that cost of audit is not
      payable by the Assessee but by the department and therefore,
      assessees interest are not affected in any way except to the
      extent of correct determination of taxable income.
      i. In view of the above discussed facts the statutory provisions
      with regard to ordering of special audit is satisfied in this case in
      view of the basic two ingredients i) Nature and complexity of
      accounts, its voluminous, doubts about the correctness of
      accounts, multiplicity of transactions, specialized nature of
      business activity of the assessee, and ii) Interest of the revenue
      for forming an opinion for the purpose of special audit u/s
      142(2A) is satisfied in this case.
      j. Therefore, I am of the considered opinion in view of foregoing




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                               Page 24 of 28
      discussion and complexity involved in information submitted and
      in the interest of revenue, that this is a fit case for invoking
      provisions of section 142(2A) of the Income Tax Act, 1961 so as
      to determine correct and true income of the Assessee company
      for the A.Y. 2013-14."
                                                   (Emphasis supplied)
21. The Assessing Officer deduced that the queries raised by the
questionnaire dated 30.05.2019 remain conclusively unanswered.                The
Assessing Officer has held that the Petitioner company was unable to cull
out the requisite details from the books of accounts to be furnished during
the course of assessment proceedings, and held that the accounts were not
only voluminous but were also complex for him to handle deftly.                   He
therefore, felt a need to have the assistance of an expert. Further, the fact of
diversion/siphoning of funds has also come out in the forensic audit report of
SEBI dated 12.12.2018 and, therefore, in order to protect the interest of the
Revenue, in-depth verification is required. It is also not in dispute that the
direction to the assessee for compulsory audit of accounts under Section 142
(2A) of the Income Tax Act does not have any financial impact on the
assessee, as the cost of audit is not payable by the assessee, but the
department. The special audit would only assist the department to correctly
determine the taxable income.           Thus, having regard to the nature and
complexity of the accounts being voluminous and the doubts about the
correctness which are evident from the material before the Assessing
Officer, we cannot say the findings of the Assessing Officer are without
application of mind.


22. There is no quarrel regarding the proposition advanced by Mr. Vohra




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                             Page 25 of 28
that the Assessing Officer has a duty to apply his mind and not to resort to
the provisions of special audit, as a matter of routine. The discretion that the
Assessing Officer exercised for ordering special audit, cannot be said to be
arbitrary or mala fide or a routine or casual exercise. In these circumstances,
on the basis of the reasons recorded in the impugned order, it cannot be said
that there was no genuine attempt on the part of the Assessing Officer to
understand the nature of his business, its method of accounting, or to
understand the nuances of the books of accounts or documents.                 The
impugned order clearly reflects the reasons for ordering a special audit. The
Assessing Officer initially issued a notice under Section 142(1) on
03.08.2018 along with detailed questionnaire including the reason for
selection of case for scrutiny under Section 143 (3). Thereafter, a fresh
notice under Section 142 (1) was issued on 30.10.2018 along with pending
and fresh queries. Since there was continued non compliance, a show cause
notice in respect of specific queries raised therein was issued on 30.05.2019.
Another notice dated 03.06.2019 in the form of corrigendum to show cause
notice was issued, calling upon the Petitioner to produce the books of
accounts.      The questionnaire raised by the Assessing Officer was not
specifically answered, and if the same had been satisfactorily answered, he
would have found the same to be useful for verification of various claims
made by the assessing companies in its return of income for the assessment
year under consideration [AY 2016-17]. The Petitioner also placed reliance
on the judgment of the Kerala High Court in Muthoottu Mini Kuries v
Deputy Commissioner of Income Tax 250 ITR 455 (Kerala) to contend that
the direction to the assessee to get accounts audited without hearing the
assessee would be unjustified. However, the ratio of the said judgment is not




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                             Page 26 of 28
applicable to the facts of the present case. Each case turns on its own facts
and the present case is distinguishable from the said judgment keeping in
view the facts and circumstances in both the cases. For the foregoing reasons
it is, thus, evident that the Petitioner was given sufficient opportunity of
being heard. Thus, the contention of violation of principles of natural justice
is also without merit.


23. Sections 142 (2A) (2D), 142 (3) and 142 (4) are the relevant provisions
dealing with the considerations that are to be weighed while directing special
audit. The Supreme Court has also laid down the guiding principles relating
to conduct of special audit. In essence, the Supreme Court has underlined
that the opinion required to be formed must be based on objective criteria,
and not subjective satisfaction. On a reading of the impugned order, it is
demonstrated that the Assessing Officer has examined the objections raised
by the Petitioner and has exercised his jurisdiction objectively on due
consideration of the records, documents and other material before him for
ordering a special audit. There is no perversity or arbitrariness in the order
of the Assessing Officer. On careful perusal of the afore-noted reasons spelt
out in the impugned order, we are of the considered opinion that the
Assessing Officer has carefully scrutinized the objections raised by the
Petitioner and has fairly and objectively arrived at the conclusion that special
audit is required.


24. Before parting, we would also like to deal with the objections raised qua
the terms of reference. We are unable to agree with Mr. Vohra that the
Assessing Officer has directed the special audit to undertake the entire work




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                             Page 27 of 28
of assessment. We do not find any reason to hold that the Assessing Officer
has shifted the responsibility of scrutinizing the accounts and passed the
buck to the special auditor, as has been contended by the Petitioner. The
special auditor who has been appointed, has been asked to give comments on
several issues. Of course, while carrying out the audit, the special auditor
would have to verify the books of accounts of the Petitioner so that the
report furnished by him, is of assistance to the Assessing Officer to
determine the taxable income. We have perused the terms of reference and
do not find the same to be inappropriate, especially having regard to the fact
that despite the honest attempt made by the Assessing Officer in
understanding the accounts of the assessee, it has not yielded the desired
results, thereby warranting the appointment of the special auditor. At this
stage, we cannot hold that there is no co-relation between the aspects which
require scrutiny and the terms of reference for the special auditor under the
law. Petitioner can raise such objections at the appropriate stage.


25. In view of the afore-going observations, the Court is of the opinion that
there is no infirmity in the order directing the special audit. The writ
petitions have no merit, and consequently the same are dismissed. The
assessee(s) in both the petitions are directed to cooperate with the special
auditor. There shall be no order as to costs.

                                                     SANJEEV NARULA, J



                                                          VIPIN SANGHI, J
AUGUST 28, 2019/nk




W.P.(C) 9358/2019 & W.P.(C) 9359/2019                            Page 28 of 28


 

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