Nut Crackers

Questions and Answers

C. B. Thakar, Advocate

Q.1 The facts are that the dealer is registered under CST Act in Andhra Pradesh as well as in Maharashtra. Order is placed by AP branch on Tamil Nadu dealer for supply of goods against H form. The supplier prepares invoice mentioning Maharashtra address. The goods are delivered by TN party in AP from where dealer exports the goods. The dealer accounts the said invoice of TN party in its books in Maharashtra and shows the same in the Maharashtra Sales Tax returns. The H form issued by Maharashtra authorities is issued to TN party. Whether the above course of action as per law?

Reply

The matter is about issue of ‘H’ form to the TN vendor. The goods are ordered from AP. The TN vendor also supplies the goods to AP place. The goods are exported from there. Therefore, the movement of goods for all the purposes is to and from AP. The general scheme of sales tax law is that the State from which physical movement of goods takes place has control over such transaction. This position is also clear from section 4 of the CST Act, 1956. The said section, which determines

situs of sale for sales tax purpose, is reproduced below.

“4. When is a sale or purchase of goods said to take place outside a State

(1) Subject to the provisions contained in section 3, when a sale or purchase of goods is determined in accordance with sub-section (2) to take place inside a State, such sale or purchase shall be deemed to have taken place outside all other States.

(2) A sale or purchase of goods shall be deemed to take place inside a State, if the goods are within the State –

(a) in the case of specific or ascertained goods, at the time of the contract of sale is made; and

(b) in the case of unascertained or future goods, at the time of their appropriation to the contract of sale by the seller or by the buyer, whether assent of the other party is prior or subsequent to such appropriation.

Explanation:– Where there is a single contract of sale or purchase of goods situated at more places than one, the provisions of this sub-section shall apply as if there were separate contracts in respect of the goods at each of such places”

In above case, the goods are received at AP. They are exported from there. Therefore, as per above section 4 of the CST Act, 1956, the situs of such export sale is in AP. Therefore, it is State of AP, which has jurisdiction over such transaction. The form facility is created to have control over the purchasing dealer. When the dealer approaches sales tax department for obtaining the blank forms, the sales tax department is in position to identify such dealer and can exercise its control over the said dealer, like they can watch the disposal of the goods purchased against said form. Therefore, impliedly it means that the purchasing dealer should obtain the forms from the jurisdictional state. In above case, even if, the vendor’s invoice is at Maharashtra office, the transaction for the purpose of sales tax laws is taking place at AP. Therefore, the dealer should use the ‘H’ form of the AP state.

This position can also be seen from another angle. The issuing of ‘H’ form to the vendor is provided in Rule 12(10) of the CST (Registration & Turnover) Rules, 1957. The said Rule is reproduced below for ready reference.

Rule 12

[(10)(a) A dealer may, in support of his claim that he is not liable to pay tax under this Act in respect of any goods on the ground that the sale of such goods is a sale in the course of export of those out of the territory of India within the meaning of sub-section (3) of section 5, furnish to the prescribed authority a certificate in Form “H” duly filled and signed by the exporter along with the evidence of export of such goods. 3[***]

(b) The provisions of the rules framed by the respective State Governments under sub-sections (3), (4) and (5) of section 13 relating to the authority from whom and the conditions subject to which any form of certificate in Form “H” may be obtained, the manner in which such form shall be kept in custody and records relating thereto maintained and the manner in which any such form may be used and any such certificate may be furnished in so far they apply to declaration in Form C prescribed under these rules shall mutatis mutandis apply to certificate in Form H.]

It can be seen that as per Rule 12(10)(b), the provisions made by State Government in respect of issue and receipt of ‘C’ form are applicable to ‘H’ form. In the CST (Bombay) Rules, 1957, Rule 4AA provides for obtaining or giving declarations in Form ‘C’. The said rule is reproduced below for ready reference.

4AA. Declaration forms to be obtained and given from delivery State. —

(1) Where a registered dealer claims to have made a sale in the course of interstate trade or commerce to another registered dealer and under instructions has delivered the goods to the purchasing dealer in another State, the declaration by the purchasing dealer to be produced by the selling dealer before the assessing authority shall be in a form obtained by the purchasing dealer from the authority in that State:

Provided that, if the purchasing dealer is not registered in the State in which the goods have been delivered, then the declaration shall be in a form obtained by him from the authority in that State in which he is registered.

(2) Where any goods are sold by a registered dealer to another registered dealer in the course of inter-State trade or commerce as a result of which the goods are delivered to the purchasing dealer in the State of Maharashtra, the declaration to be given by the purchasing dealer if he is registered in this State, shall be in a form obtained under sub-rule (1) of rule 4.]

As per sub-rule (2) of above rule 4AA, the ‘C’ form of Maharashtra is to be issued, if the goods are delivered in Maharashtra and the purchasing dealer is registered in Maharashtra. Thus, the rule does not contemplate to issue ‘C’ forms from Maharashtra, if the delivery of the said goods is not in Maharashtra. If at all, the dealer is not registered in the actual state of delivery then he can issue ‘C’ form of Maharashtra. The same position will also apply to ‘H’ form.

In above case, the goods are delivered in AP, as well as the dealer is also registered in AP under CST Act, 1956. Looking to the above legal position, the dealer should issue ‘H’ form from AP. The export turnover in relation to above purchases against ‘H’ form should also be shown in AP returns and not in VAT returns of Maharashtra.

Q.2. The dealer has purchased plant along with land from Financial Institution in auction. The original owner of plant was declared sick unit and was liable to discharge sales tax dues for past years. The Sales Tax Department is contemplating to recover the said dues from the dealer who has purchased the plant and land in auction. Whether the department is justified in such demand?

Reply

Though the issue raised is in relation to sales tax laws it is required to be seen in light of specific provisions under specific State Sales Tax Act which is at present referred to as VAT Act. In this query the issue can be examined in light of provisions of Maharashtra Valued Added Tax Act, 2002 (MVAT Act, 2002).

The facts appears to be that there may be a unit which has been closed due to financial losses or for any other reason. When the sick unit is not in position to repay the loans taken from the financial institutions like IDBI/UTI, its property being mortgaged to the financial institutions, the said financial institutions take the charge of the assets. These units then dispose of assets. Normally, this may be disposed of by auction sale etc.. Under the authority as per the agreement and as per the relevant Finance Regulation Act the financial institutions are in position to dispose of the assets to recover the loan. However such unit may also be indebted to the sales tax department about its tax arrears. The issue which is raised is whether such arrears can be recovered from the purchaser of the assets from the financial institution.

To give an opinion on above issue, it is necessary to refer to certain relevant provisions of the sales tax law. Under sales tax laws, normally the person succeeding (transferee) in the business is also made liable to all the arrears of the transferor. For this purpose specific provisions are made in the sales tax laws. In relation to the MVAT Act, 2002. The reference can be made to section 44(4)
of the said Act. The said section is reproduced as under:

“44. Special provision regarding liability to pay tax in certain cases –

(4) Where a dealer, liable to pay tax under this Act, transfers or otherwise disposes of his business in whole or in part, or effects any change in the ownership thereof, in consequence of which he is succeeded in the business or part thereof by any other person, the dealer and the person succeeding shall jointly and severally be liable to pay the tax including any penalty, sum forfeited and interest due from the dealer under this Act or under any earlier law, up to the time of such transfer, disposal or change, whether such tax including any penalty, sum forfeited and interest has been assessed before such transfer, disposal or change but has remained unpaid, or is assessed thereafter.”

Thus, it is provided that if a dealer transfers his business then the transferee taking over his business is made liable for all the arrears of the transferor till the date of transfer, whether assessed prior to such date of transfer or after the date of transfer.

The important ingredients to attract section 44(4) are that there should be transfer of business by the transferor to transferee. In other words the transferee should take over his business. The takeover of business is something which has many aspects. In contrast there may be only disposal of land, building and plant and machinery etc.. This is referred to as disposal of the assets. If it is only the disposal of assets then it cannot be said that the purchaser is the transferee of the business. In such case he is only purchaser of the assets as any other normal dealer and no liability can befall upon him, as can fall in case of transfer of business. However, when a dealer purchases his assets, some time an issue arises whether it amounts to transfer of business to him by the transferor so as to liable to pay the arrears or only purchase of assets. This issue has been discussed at various levels. A reference can be made to following few important judgments.

1. D’Que Industries (S.A.991 of 1987 dt.12-9-88)

In this case the dealer has purchased the assets including land, building and plant and machinery. The said assets were purchased in the auction made by the financial institution for recovery of its loan amount. The sales tax department on above facts held the dealer as transferee of the sick unit of whose assets were sold by the financial institution and they wanted to make the dealer liable as a transferee. The M.S.T. Tribunal held that when it is only purchase of the assets there is no transfer of business. To become a transferee of the business, Tribunal, amongst others, observed that the transfer of business can take place when there is transfer of assets as well as goodwill of the business and if that is not the position then it is only the purchase of assets and not transfer of business. In this particular case the Tribunal held that there is no transfer of business but only purchase of assets and hence the dealer cannot be liable as transferee of the business.

2. Alpha Silicons vs. Assistant Commissioner of Sales Tax (Recovery), Gulbarga (77 STC 68) (Kar.)

In this case the dealer purchased the assets of a sick unit in the auction held by a financial institution. The liabilities about arrears were thrust upon this dealer and hence he approached the High Court. The High Court observed that since there is transfer of business the dealer is liable to arrears also. In this case the Hon’ble High Court observed that transfer of business takes place when there is, along with assets, transfer of goodwill etc.. Therefore from the judgment it appears that if the purchase of assets is along with goodwill then it will be case of transfer and not purchase of assets and in that case the liability will follow.

3. V. Adinarayan & Others vs. Andhra Bank & Others (142 STC 469) (A.P.)

In this case the dealer has purchased the assets from the bank under Securitisation Act. The liability as a transferee was tried to be thrust upon the dealer. High Court held that since there is no transfer of goodwill etc. there is no question of transfer of business. It is only case of purchase of assets and hence the liability cannot be attracted to him for arrears.

4. Shreya Paper Mart (144 STC 331) (SC)

This is a recent case decided by Hon’ble Supreme Court. The Supreme Court has dealt with the issue similar to where the assets were sold by the financial institution. Supreme Court has observed upon the legal position elaborately. It is held that if there is transfer of business then the liability can be attracted as a transferee. Supreme Court has observed about the nature of transfer. As per the observations of the Supreme Court it appears that there should be a transfer of running business with a view to gain profit out of the same and it should be along with the goodwill.

This is the latest case of the Hon’ble Supreme Court. As per the said judgment now it can very well be said that if the financial institution has only sold the assets after the unit is closed, then there is no possibility that there is transfer of business.

Therefore in relation to above query, we opine that a purchaser of assets of sick unit in auction by Financial Institution cannot be liable to arrears of sick unit and sales tax department cannot be justified in asking such dues from such purchaser.