In pursuit of knowledge

Abatement of Settlement Applications – An alternative to present litigation

Direct Taxes

S. R. Wadhwa
Advocate*

Income Tax Settlement Commission-a high powered judicial forum, manned by very senior officers of the Income-tax Department, was set up in 1976 at Delhi to settle, once for all, complex income-tax/wealth tax cases or those requiring prolonged and cumbersome investigation. Since 1981, it has four Benches each functioning at Delhi, Mumbai, Kolkata and Chennai. Over the years, the pendency of settlement applications grew despite directory provision, introduced w.e.f. 1-6-2002 in sub-section (4A) to section 245D of the Income-tax Act, requiring the Commission to settle every case within 4 years from the end of the year of its admission, where it was possible.

Reasons for increasing pendency of settlement applications

The main reason for the increase in pendency was the in-ordinate long time taken by the Commission in admitting the applications for settlement leaving little time to settle the cases. The legal justification was provided by the judgement of the Supreme Court in CIT vs. Express News Papers Ltd. (1994) 206 ITR 443(SC) delivered in February, 1994 where, describing the scheme of settlement, the Supreme Court observed that where an applicant did not make a true and full disclosure of his income not disclosed before the income-tax authorities, his application was not maintainable and should be rejected at the threshhold. The Benches of the Commission started in-depth examination of the applications at the admission stage itself to ascertain if the disclosure was true and full. So much so, a Special Bench was set up at Delhi to lay down the guidelines and procedure for examination before admission of settlement applications.

Another reason was the un-settled character of the Settlement Commission itself due to the reduction in the normal tenure of the Members of the Commission from four years to only two years and suffering several transfers as well with in this short period.

Remedial action – Abatement of un-disposed of applications

The Central Government took several steps to remedy the situation through the Finance Act, 2007 but, in the process, threw the baby with the tub water.

The admission of settlement applications was almost made automatic on the applicant paying the entire tax and interest due on the basis of the additional tax disclosed along with the settlement application. To reduce the intake of fresh applications, their scope was restricted to the pendency of first assessment proceeding before the assessing authority. Search and seizure cases were excluded from the jurisdiction of the Commission. The additional tax payable for a settlement application was increased from Rs. 1 lac to Rs. 3 lakhs. The existence of complexity of investigation as a condition for admission of the settlement application was given up. A mandatory time limit of 12 months for passing the final order of settlement was also laid down in section 245D(4A)(ii) of the Act. These provisions were, however, made applicable to the settlement applications filed on or after 1st June, 2007.

In respect of the applications filed earlier, on or before 31st May, 2007, the Finance Act 2007, required the entire tax and interest to be paid on the basis of additional income disclosed on or before 31st July, 2007 failing which, such applications were to abate. Having collected the tax and interest due, clause (i) of section 245D (4A), read with section 245HA (1) (IV), provided for abatement of such applications as were not disposed of on 31-3-2008. This was a very harsh provision and was made without due regard to the fact that there were nearly 3700 such applications pending, and keeping in view the normal annual disposal of about 500 applications, it would be totally unrealistic and virtually impossible for the Commission to dispose them off by 31st March, 2008.

The consequences of the abatement were disastrous. On abatement of the settlement application, vide sub-section (2) to section 245HA, the proceedings for all the years involved there-in were to be restored to the files of the income tax authorities, i.e., Assessing Officer or the Commissioner of Income-tax (Appeals), where they were pending at the time of making the settlement application. Such authorities could use all the material and information including the material submitted before the Settlement Commission in strict confidence while making the true and full disclosure of income not disclosed before the tax authorities. Besides, such unfortunate applicants have been made to suffer the usual process of assessments, appeals etc. to the CIT (A), Tribunal, High Court and Supreme Court. They are also to face penalty for concealment of income and criminal prosecution for which, Settlement Commission had the power to grant immunity. Thus, for absolutely no fault of theirs, the applicants whose applications abated, and who had been awaiting patiently for several years for their cases to be settled by the Commission, would now suffer prolonged and ruinous litigation – a process for the avoidance of which they had gone to the Commission and made a true and full disclosure of their undisclosed income and paid full tax and interest thereon.

A thousand and odd writ petitions in the High Courts/Supreme Court

More than a thousand writ petitions appear to have been filed against the abatement in various High Courts/Supreme Court causing avoidable additional work in these Courts that are already suffering from huge pendency of cases The constitutional validity of the abatement provision has been challenged, among others, on the following grounds:-

(i) Apprehension of not getting a fair and just hearing or treatment from the Assessing Officer who, is in a sense, an adversary of the applicant before the Commission

(ii) Personal and institutional bias against the applicant for his approaching the Commission and disclosing the material not disclosed to the Assessing Officer.

(iii) Confidential material/information disclosed in strict confidence to the Commission being made available to the Assessing Officer to be used not only for making assessments but also for levying penalty and criminal prosecution. The power of immunity vested in the CIT is largely illusory. Being a party before the Commission, and subject to the jurisdiction of the internal audit as also the audit by the Comptroller General of India, he is not likely to exercise the power objectively and fearlessly.

(iv) Income of the applicant being determined by the Assessing Officer or CIT (A) not having wide knowledge and experience of the scale that the members of the Commission have, being equivalent in status to the members of the Central Board of Direct Taxes.

(v) Proceedings before the Assessing Officer are conducted by one person and are quasi-judicial. Those before the Commission are by a Bench of three independent persons and the proceedings are judicial in nature.

(vi) Commission’s order is final and conclusive and application is decided on one-stop basis. Regular assessments after abatement would have to go through a plethora of appeals before a final decision gets arrived at.

(vii) Commission’s jurisdiction was exclusive and plenary while the income tax authority, after abatement, will have no such exclusive jurisdiction or plenary power.

(viii) Settlements, unlike regular assessments, are through adjudication. The issues by the Commission are thus viewed in an entirely different way from those by the Assessing Officer.

(ix) The Assessing Officer being a litigant himself before the Commission may not be realistic and provide fair and even-handed treatment to the applicant.

(x) The criteria for abatement, being the inability of the Commission to dispose of the applications, is not a valid and reasonable one in the eyes of law and suffers from the vice of inequality violative of Article 14 of the Constitution.

(xi) The choice of the applicants where applications abated was totally arbitrary. The applications were not taken up for disposal by the Commission chronologically and there was an element of pick and choose

(xii) The fixing of time limit of less than one year for disposal of all pending applications was totally unrealistic and impractical.

(xiii) Alternate methods of solving the problem of pendency like the creation of additional Benches and/or having a single member Bench for disposal of small cases were neither explored not made known to the public.

(xiv) No reasons, whatsoever, were given to the Parliament explaining the object of the abatement provisions.

Even if the abatement provisions are held valid by the Apex Court, the most laudable objective of expeditious determination of tax liability and payment of tax would be totally frustrated. In some cases, complex as they are, 22 to 30 years of litigation may ensue before the regular assessments made after abatement reached finality.

Alternative to the litigation

Let us, therefore, examine if all these litigations causing great hardship to the unfortunate applicants is worthwhile or there is some better alternative to the litigation in the High Courts/ Supreme Court. For this purpose, let us examine the quantitative dimension of the problem. The bench-wise work-load of settlement applications both with regard to the old applications which were to have abated and the new applications filed on or after 1-6-2007, is as under:-

Bench wise institution and disposal of settlement applications during the F.Y. 2007-08*

(i) Applications received on or before 31-5-2007 and pending on 31-3-2008

Particulars

Delhi

Mumbai

Kolkata

Chennai 

Total

Application received on 1-4-2007

1103

738

311

286

2438

Add: Applications received during 2007-08

685

266

265

55

1271

Total for disposal

1788

1004

576

341

3709

Less: disposal during F.Y. 2007-08

563

340

446

326

1675

Balance as on 31-3-2008 

 

 

 

 

 

– eligible for abatement

1225

664

130

15

2034

 

Particulars

Delhi

Mumbai

Kolkata

Chennai 

Total

Pendency as on 31-3-2007

Addition during 2007-08

15

8

3

26

Less: disposal during F.Y. 2007-08

2

2

Balance as on 31-3-2008

13

8

3

24

  • Information received from the Settlement Commission under section-7 of the Right to Information Act, 2005

On 31-3-2008, there were only 2034 applications pending which would have abated in view of section 245HA(1)(iv) of the Act or stay granted by the High Courts in the writ petitions admitted against abatement.. In several cases, the High Courts while granting stay against abatement of the settlement applications, gave liberty to the Commission to dispose them off pending the disposal of the writ petitions. Therefore, during the financial year 2008-09 some of the pending applications would have been disposed off in view of the permission granted by the High Courts. Some applications would have abated without the concerned applicants having filled any writ petition against the abatement. We can therefore safely assume that there would not be more than 1500-1600 settlement applications pending on 31st March, 2009 with the Settlement Commission. Keeping in view the disposal of 1675 cases during 2007-08, it is safe to assume that 1500 odd applications involving litigation before the Courts would be equivalent to about one year’s disposal. The institution of 26 new applications after 1-6-2007 has been so small that it does not justify the existence of the Commission- at least not all the four Benches.

Since all the four Benches of the Settlement Commission are continuing, the plain and simple logic of solving the problem is for the Central Government to recommend to the Parliament to re-amend the provision regarding the settlement applications filed on or before 31-5-2007. The abatement provision should be withdrawn with retrospective effect. The Commission may be given two years time, to be on the safe side, to dispose off all such applications filed on or before 31st May, 2007 and if it is unable to do so, instead of abatement, the applications will become time barred and the additional income as disclosed in the settlement application would be deemed to have been accepted. Not much additional revenue is involved in the applications after the payment of tax and interest due on the basis of the additional income disclosed in them.

The amendment should be applicable to all cases where the writ petitions have been filed against the abatement and stay has been granted by the High Courts. In respect of others, where the applications have abated and no writ petitions have been filed, an option may be given to such applicants to come back to the Commission to settle the additions made by the assessing authorities/CIT (A) instead of adjudicating them in the normal course of appeals etc. A period of three months may be given, after the amended law is passed, to such applicants to exercise the option.

The All India Federation of Tax Practitioners, in its memorandum dated 14-1-2008 to the Union Finance Minister making suggestions for the Annual Budget, 2008, had suggested that the period of abatement should be extended by three years from 31-3-2008 to 31-3-2011. The representatives of the Federation had also met the Chairman, Central Board of Direct Taxes in this regard. Only if the suggestion of the Federation was accepted, filing of more than 1000 writ petitions would have been avoided.

It is not too late even now.