Civil Appeal No. 1992 of 2020 @ SLP(C)No.23705 of 2019 Cognizant Technology Solutions India Pvt. Ltd.  Vs.  Deputy Commnr. Of  Income Tax Large Tax Payer Unit 1.

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NON-REPORTABLE

IN THE SUPREME COURT OF INDIA

CIVIL APPELLATE JURISDICTION

CIVIL APPEAL NO.  1992  OF 2020 (Arising out of Special Leave Petition(Civil) No.23705 of 2019)

COGNIZANT TECHNOLOGY SOLUTIONS  INDIA PVT. LIMITED     …Appellant

                               VERSUS

DEPUTY COMMISSIONER OF INCOME TAX  LARGE TAX PAYER UNIT 1               …Respondent

O R D E R  

Uday Umesh Lalit, J.

1. Leave granted.

2. This  appeal  arises  out  of  the  final  judgment  and  order  dated

06.09.20191 passed by the High Court2 in Writ Appeal No.2063 of 2019.

3. The  appellant  is  engaged  in  the  business  of  development  of

computer software and related services.  In the Financial Year 2016-17, the

appellant approached the High Court with a Scheme of Arrangement and

Compromise under Sections 391 to 393 of  the Companies Act,  1956 to

1 Corrected vide further order dated 12.09.2019 2 The High Court of Judicature at Madras

Civil Appeal No. 1992 of 2020 @ SLP(C)No.23705 of 2019 Cognizant Technology Solutions India Pvt. Ltd.  Vs.  Deputy Commnr. Of  Income Tax Large Tax Payer Unit 1.

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buy-back its shares.  The High Court sanctioned the Scheme on 18.04.2016

in  Company  Petition  No.102  of  2016,  pursuant  to  which  the  appellant

purchased 94,00,534 shares at a price of Rs.20,297/- per share from its four

shareholders  and  made  a  total  remittance  of  Rs.19,080  crores

approximately.  The details in that behalf were:-

Shareholder Shares Purchased

(No. of Shares)

Consideration  (Amount in Rs.)

Tax deducted at Source (Amount in Rs.)

Cognizant Technology Solutions Corporation

(“CTS USA”)

37,00,747 7511,40,61,859 810,73,37,402

MarketRx Inc (USA)

2,38,521 484,12,60,737 52,33,24,388

Cognizant (Mauritius) Limited (Mauritius)

53,01,778 10761,03,91,036 0 (Treaty benefit claimed)

CSS Investments LLC, Delaware (USA)

1,59,478 323,69,24,966 34,95,01,528

Total 94,00,534 19080,26,38,598 898,01,63,318

According to the appellant, this buy-back of shares was effected in

May 2016.

4. Thereafter, the appellant made statutory filing under Form 15 CA

(under Rule 37BB of the Income Tax Rules, 1962) after obtaining requisite

certificate from a Chartered Accountant in Form 15CB furnishing details of

remittances made to non-residents.   

5. On  21.11.2017  a  letter  was  received  by  the  appellant  from  the

Civil Appeal No. 1992 of 2020 @ SLP(C)No.23705 of 2019 Cognizant Technology Solutions India Pvt. Ltd.  Vs.  Deputy Commnr. Of  Income Tax Large Tax Payer Unit 1.

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Deputy Commissioner of Income Tax, Large Taxpayer Unit-1, Chennai in

connection with non-payment of tax on the remittances made to the non-

residents, in Financial Years 2015-16 and 2016-17.  The letter stated:-

“…  …On  verification  of  15CA data  available  with  the department, it is noticed that your company has made the following remittances to non-residents during the financial years 2015-16 and 2016-17.

Date of Remittance

Name of the non-resident company receiving the

remittance

Amount remitted (Rs.)

Tax made on remittance

(Rs.)

17.02.2016 Cognizant (Mauritius)  Ltd.

335,36,38,361 Nil

19.05.2016 Cognizant (Mauritius)  Ltd.

10761,03,91,036 Nil

19.05.2016 Cognizant  Technology Solutions  Corporation, USA

7511,40,61,859 810,73,37,402

19.05.2016 Market Rx Luc, USA 484,12,60,737 52,33,24,388

19.05.2016 CSS investment LLC,  USA

323,69,24,966 34,95,01,528

Total 19415,62,76,959 898,01,63,318

The data available with the department shows that you have not deducted/paid any tax on the remittances made to M/s Cognizant (Mauritius) Ltd. on 17.02.2016 and 19.05.2016 whereas in the case of remittances to the concerns in USA, you have only deducted/paid tax @ 10% (plus surcharge & cess).

In this regard, I request you to kindly furnish the following information:

a) The dates and amounts of remittances to the non-residents during  the  FYs.  2015-16  &  2016-17,  along  with  their

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residential status.

b) The nature and purpose of the said remittances.  Copies of the  documents  submitted  to  the  RBI  for  obtaining  the permission and remitting the amounts.

c) Whether the above remittances are in accordance with any agreement, scheme etc.? If so, please furnish the copies of the same.

d) Dates  and  amounts  of  taxes  deducted/paid  into  govt. account,  along  with  evidences,  and  the  sections  under which the said tax was deducted and/or claimed exempt, as the case may be.

e) The rate(s) at which the above tax is deducted/paid into the govt. account, in each case; and reasons for deviation from the  statutory  requirement  of  tax,  if  any,  or  non- deduction/non-payment, as the case may be.”

6. The requisite  details  were furnished by the appellant  vide letters

dated 01.12.2017 and 05.12.2017 whereafter meetings were held between

the officials of the appellant and the officers of the Department.  Later, a

communication  was  addressed  by  the  Department  to  the  appellant  on

22.03.2018.  After referring to the remittances made by the appellant to its

four shareholders, it was stated:-

“2. The company has not remitted any tax u/s. 115-O of the Act till date, even though the tax @ 15% u/s. 115-O is to be remitted into the central Govt. Account within 14 days from the date of payment to the shareholders.

3. The assessee company was under the impression that since its scheme of “arrangement and compromise” between the shareholders and the company, was in accordance with

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sec.391 to 393 of the Companies Act, and approved by the Court, the provisions of section 115-QA, 115-O or 2(22) of Income Tax Act are not applicable to its case.  During the personal  discussion  between  the  company  and  the AO/JCIT/CIT (LTU),  it  was  brought  to  the  notice  of  the Company that:

 Provisions  of  sections  115-QA of  the  IT Act,  which were  introduced  w.e.f.  01.06.2013,  defines  the  ‘buy- back’, as the one done in accordance with sec.77A of the  Companies  Act  (valid  upto  31.05.2016).  W.e.f. 01.06.2016,  any  buy-back  of  own  shares  will  attract 115-QA.

 Provisions of sec.2(22)(d),  clearly postulates that any distribution  on  reduction  of  capital,  to  the  extent  of accumulated  profits  will  amount  to  dividends.   The only exception to this is the buy-back u/s. 77A of the Companies Act.  Provisions of sec.2(22)(d) are:

S.2(22)(d):  any  distribution  to  its  shareholders  by  a company on the reduction of its capital, to the extent to which the company possesses accumulated profits  which arose after the end of the previous year ending next before the  1st day  of  April,  1933,  whether  such accumulated profits  have been capitalised or not:

 Even otherwise, provisions of sec. 2(22)(a) of the Act, which stipulate that any distribution to the shareholders is a dividend, if it is contended that it was not a case of reduction of capital.  Provisions of sec.2(22)(a) are:

S.2(22)(a):  any  distribution  by  a  company  of accumulated  profits  whether  capitalised or  not,  if  such  distribution  entails  the release  by  the  company  to  its shareholders  of  all  or  any  part  of  the assets of the company;

 Once,  the  provisions  of  sec.2(22)(d)  or  2(22)(a)  are

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applicable,  the  distributor  is  required  to  pay  tax u/s.115-O of the Act.

 In the present case, the assessee’s purchase of its own shares, which is not in accordance with sec.77A of the Companies  Act,  will  amount  to  dividends within  the meaning  of  sec.2(22)(d)  or  2(22)(a)  of  the  Act,  and consequently, liable for tax u/s. 115-O of the Act in the hands of the assessee company.”

After considering factual aspects it was stated :-

“11.  This  clearly shows that,  to  the  extent  of  face  value (issued price), the paid-up share capital will be utilized and the  balance  will  be  paid  from  the  reserves,  which  are nothing but accumulated profits in the present case.  Here the payment from the paid-up shares capital is nothing but reduction of capital and the latter (i.e.  payment from the reserves  being  accumulated  profits)  is  distribution  of profits.

12. When any company reduces the ‘share capital’ as per the provisions of the Companies Act, by way of reducing the face value of shares or by way of paying off part of the share capital, it amounts to extinguishment of the rights of the shareholder to the extent of reduction of share capital. Therefore, it is regarded as transfer under section 2(47) of the IT Act and would be chargeable to tax.”

Finally, it was concluded:-

“18. Thus, the payments made to the shareholders, under purchase of  shares through the  scheme of  “arrangements and  compromise”,  is  a  dividend  within  the  meaning  of section 2(22)(d)/2(22)(a) of the Act, requiring to remit the taxes in to the government account u/s. 115-O of the Act. Further,  since  the  company has  failed to  remit  the  taxes within the stipulated period, the company is ‘deemed to be an assessee in default’, u/s. 115-Q of the Act.  Therefore the

Civil Appeal No. 1992 of 2020 @ SLP(C)No.23705 of 2019 Cognizant Technology Solutions India Pvt. Ltd.  Vs.  Deputy Commnr. Of  Income Tax Large Tax Payer Unit 1.

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assessee company is required to remit the taxes (calculated @ 15% of the total payments of Rs.19415,62,77,269/- to the shareholders,  and surcharge etc as per the Act) along with the interest payable u/s. 115-P of the Act, immediately, failing  which  the  department  will  proceed  with  the collection  and  recovery  of  the  taxes,  including  coercive steps, as per the provisions of the Act.”  

7. Said  communication  dated  22.03.2018  was  received  by  the

appellant on or about 26.03.2018 and soon thereafter the bank accounts of

the appellant were attached by the Department.

8. It must be stated here that  while the meetings between the officials

of  the  appellant  and  the  officers  of  the  Department  were  going  on,  an

application  was  preferred  by  the  appellant  on  20.03.2018  before  the

Authority  for  Advance  Ruling  (AAR)  under  Section  245Q  of  the  Act3

seeking a ruling on the issue whether the appellant was liable to pay tax on

buy-back of its shares under Section 115QA or Section 115-O or any other

provision of the Act.   

9. The appellant challenged the communication dated 22.03.2018 by

filing Writ Petition No.7354 of 2018 in the High Court submitting  inter

alia that while the issue was pending before the AAR under Section 245Q

of the Act, in view of the bar provided under Section 245RR of the Act, the

matter  could  not  have  been considered.   It  was  also  submitted  that  the

3 The Income Tax Act, 1961

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appellant was never put to notice whether it would be liable under Section

115-O  of  the  Act.   It  was  further  submitted  that  all  the  while  the

Department was only soliciting information which the appellant had readily

furnished and at no stage the appellant was put to notice that its liability

would be determined in any manner.

10. The Writ Petition came up before a Single Judge of the High Court

on 03.04.2018 when following interim directions were issued:-

“11. In my considered view the impugned proceedings has crystallized in the form of a demand for payment of tax, and if the petitioner has to be granted an interim protection till  the writ  petition is  finally  heard,  the  same has  to  be conditional  and  cannot  be  unconditional.   Assuming without admitting the petitioner had to avail an appellate remedy  under  the  Act  and  prays  for  appropriate  interim orders  before  an  appellate  authority,  then  the  appellate authority  is  entitled  to  grant  an  order  of  stay,  which  is invariably conditional on account of guidelines issued by the Central Board of Direct Taxes (CBDT) with a view to maintain uniformity in the matter of grant of interim orders. As  per  the  latest  guidelines  prescribed  by CBDT,  it  has recommended  that  20% of  the  demand,  which  has  been made shall be directed to be remitted by the assessee for grant of stay of the remaining demand.  Though this cannot be a universal rule, invariable in most cases, the authorities have adopted the 20% formula.  However, in certain cases, this Court has interfered with such orders and reduced the amounts payable by the assessee and in certain other cases, where no stay has been granted by the authority and the assessee has approached the Court for grant of interim stay, the Court has imposed condition by directing payment of more than 20% of the demand.  Therefore, the facts of each case  have  to  be  considered  while  granting  interim order bearing  in  mind  the  interest  of  the  assessee  as  well  as

Civil Appeal No. 1992 of 2020 @ SLP(C)No.23705 of 2019 Cognizant Technology Solutions India Pvt. Ltd.  Vs.  Deputy Commnr. Of  Income Tax Large Tax Payer Unit 1.

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safeguarding the interest of the Revenue.

12. Thus,  considering the  facts  and circumstances  of  the case, there will be an order of interim stay of the impugned proceedings subject to the condition that the petitioner pays 15% of the tax demanded and furnishes a Bank Guarantee or  security  by  way of  Fixed  Deposits  for  the  remaining taxes (only), to be paid.  For the purpose of complying with the above condition, the attachment of the Bank account in JP Morgan Chase Bank N.A., J.P. Morgan Tower, 8th Floor, Off  C.S.T Road,  Kalina,  Santacruz  East,  Mumbai  –  400 098 shall stand lifted forthwith.  However, the attachment in respect of other Bank accounts viz.,

(a) State Bank of India, CAG Branch, Chennai.

(b) Deutsche Bank, Ground Floor,  Door No.4 & 4A, Western Tower,  Sunny Side, Shafi Mohammed Road, Thousand Lights, Chennai – 600 006.

(c) Corporation Bank, Corporate Banking Branch, 38 & 39 Whites Road, Chennai-600 014.

(d) City Bank N.A., No.163, Anna Salai, Chennai-600 002.

(e) HDFC Bank, No.115, Dr. Radhakrishnan Salai, 9th Floor, Mylapore, Chennai-600 004,

shall  continue till  the compliance of  the above direction. Similarly, the attachment of the nine Bank deposits viz., (1) HDFC Limited, (ii)  HDFC Limited,  (iii)  HDFC Limited, (iv)  HDFC  Limited,  (v)  HDFC  Limited,  (vi)  HDFC Limited, (vii) Bajaj Finance Limited, (viii) Bajaj Finance Limited,  (ix)  Bajaj  Finance  Limited  shall  also  continue subject to the lien being created for the remaining amount of taxes.  The remittance of 15% of the tax demanded shall be  retained in  a separate  account  and shall  abide by the orders to be passed in the writ petition.”

Civil Appeal No. 1992 of 2020 @ SLP(C)No.23705 of 2019 Cognizant Technology Solutions India Pvt. Ltd.  Vs.  Deputy Commnr. Of  Income Tax Large Tax Payer Unit 1.

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11. The Single Judge by his decision dated 25.06.2019 dismissed the

Writ Petition as not being maintainable and relegated the appellant to avail

the remedy before the Appellate Authority under the Act.  However, during

the course of his decision, the Single Judge concluded that there was no

need for issuance of any notice before making a demand under Section

115-O of the Act and the notice issued on 21.11.2017 calling for details

whereafter meetings were convened, was quite adequate.  He rejected the

submission that there would be a bar in terms of Section 245RR of the Act.

The Single Judge did not find any merit in the contention that the shares

purchased pursuant to the order of the Company Court could not be treated

as dividend.  While relegating the appellant to avail the remedy before the

Appellate Authority it was observed:-

“33. … … the Appellate Authority shall take into account the  amount  deposited  in  pursuance  of  the  order  referred supra, while entertaining the appeal.  With regard to Fixed Deposits,  the  respondent  shall  maintain  status-quo  as  on date for a period of two weeks. … …”   

12. The appellant,  being aggrieved, challenged the aforesaid view by

filing Writ Appeal No.2063 of 2019.  While discussing the issues that came

up for consideration, the Division Bench observed that the Single Judge

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after having found the Writ Petition to be not maintainable, ought not to

have gone into merits.  As regards the nature of the communication dated

22.03.2018 and maintainability of an appeal challenging the same, it was

observed:-

“11. The  learned  Senior  Counsel  appearing  for  the appellant would submit that it is not known as to whether the  impugned  order  dated  22.03.2018  is  a  show  cause notice  or  final  order.   Though there  appears  to  be  some element of contradiction in the counter affidavit filed, the said order appears to be a final one.  Now it is also the contention of the learned Additional Solicitor General that it is only a final order.  We are also of the view that the further action taken would also indicate that the order under challenge was a final one.  If it is only a show cause notice, then  there  is  no  need  to  challenge  it  and  instead  the consequential  freezing  alone  requires  to  be  questioned. The  further  question  as  to  whether  the  order  under challenge  violates  the  principles  of  natural  justice  or requisite procedure contemplated under the Act is a matter for  consideration  before  the  Appellate  Authority.   The learned Single Judge has rightly observed that the appeal can be entertained and decided on merit as the appellant has already deposited a sum of Rs.495 crores.”

13. The  view  taken  by  the  Division  Bench  of  the  High  Court  is

presently under appeal.  On 04.10.2019, an affidavit of undertaking, filed

on behalf of the appellant was taken on record in which it was submitted:-

“In  the  event  this  Hon’ble  Court  is  gracious  to  pass  an order  that  the fixed deposits  over  which a lien has been created,  pursuant  to  the  Interim  Order  passed  by  the Learned Single Judge (continued by the Division Bench), is

Civil Appeal No. 1992 of 2020 @ SLP(C)No.23705 of 2019 Cognizant Technology Solutions India Pvt. Ltd.  Vs.  Deputy Commnr. Of  Income Tax Large Tax Payer Unit 1.

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vacated  as  an  interim  measure  to  enable  the  Petitioner Company to run its business and operations, the Petitioner undertakes that in the event this Hon’ble Court is satisfied that any security must be offered by the Petitioner ex debito justitiae at the time of the disposal of the Special Leave Petition,  the Petitioner  will  unqualifiedly,  without demur, furnish such security/fixed deposits  to  the  satisfaction  of the Registrar of the Hon’ble Court as this Hon’ble Court may be so pleased to direct.”

However, by order dated 14.10.2019, this Court observed:-

“It  is  a  matter  of  record  that  pursuant  to  order  dated 03.04.2018 passed by the Single Judge of the High Court of Judicature at Madras in Writ Petition No.7354 of 2018, a sum of Rs.2806,40,15,294/- stands deposited and invested in the form of fixed deposit receipts.”

It was then directed:-

“Pending  further  consideration,  the  amount  which  is presently lying in deposit shall be maintained in the same form.”

14. We heard Mr. Gopal Subramanium, learned Senior Advocate for the

appellant and Mr. Zoheb Hossain, learned advocate for the Department.   

15. It  was  submitted by Mr.  Subramanium, learned Senior  Advocate

that the instant  transaction would not  come within the scope of  Section

115-O of the Act.   It was submitted that the appellant was never put to

notice about the proposed determination in terms of Section 115-O of the

Act; that the communication dated 22.03.2018 could not be said to have

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determined the  liability of the appellant under Section 115-O of the Act

and  consequently  the  appellant  could  not  have  been  relegated  to  the

appellate remedy as directed.   It  was submitted that  the communication

dated 22.03.2018 could, at best be treated as an intimation of the action

proposed to be taken resort to by the Department.  These submissions were

countered by Mr. Zoheb Hussain, learned Advocate.  According to him, the

matter would come within the ambit of Section 115-O of the Act.  He also

relied upon Section 115-Q of the Act to submit that in case the assessee-

company had not  paid tax on distributed profits  in accordance with the

provisions of Section 115-O, the assessee-company would be deemed to be

“an assessee in default” in respect of the amount of tax and all provisions

relating  to  collection  and  recovery  of  income tax  would  apply.   As  an

extension of the concept, it was submitted that the Department was justified

in issuing the communication dated 22.03.2018 followed by attachment of

the accounts of the appellant.   

16. On the issue whether communication dated 22.03.2018 was in the

nature of determination of the liability, both the learned counsel were heard

at considerable length, at the end of which it  was agreed by Mr. Zoheb

Hossain,  learned  Advocate  for  the  Department,  that  the  communication

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dated  22.03.2018  could  be  treated  as  a  show  cause  notice  and  the

Department be permitted to conclude the issue within a reasonable time,

provided the interim order passed by the Single Judge of the High Court on

03.04.2018 was continued.  The course suggested by the learned counsel

for the Department was acceptable to the learned Senior Counsel for the

appellant.

17. It was, therefore, suggested that the appellant may file an affidavit

of undertaking to withdraw the proceedings initiated by it before the AAR

and the Department may also file an appropriate affidavit stating that it was

willing  to  treat  the  communication  dated  22.03.2018  as  a  show  cause

notice.   An  appropriate  affidavit  of  undertaking  to  withdraw  the

proceedings  initiated  before  the  AAR has  since  then  been  filed  by  the

appellant.   An affidavit has also been filed on behalf of the Department

stating:-

“The communication dated 22.03.2018 may be treated as a show  cause  notice  and  the  assessee  will  be  given  an opportunity of being heard and a fresh order will be passed within two months from the date of the judgment of this Hon’ble Court.”

18. In the peculiar facts and circumstances of the present case, while

disposing of this Appeal, we direct:-

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a) The communication dated 22.03.2018 shall  be treated as a show

cause notice calling upon the appellant to respond with regard to

the aspects adverted to in said communication;

b) The appellant shall be entitled to put in its reply and place such

material, on which it seeks to place reliance, within 10 days from

today;  

c) The  appellant  shall  thereafter  be  afforded  oral  hearing  in  the

matter;

d) The matter shall thereafter be decided on merits by the concerned

authority within two months from today;

e) Pending  such  consideration,  as  also  till  the  period  to  prefer  an

appeal from the decision on merits is not over, the interim order

passed by the Single Judge of the High Court on 03.04.2018 and as

affirmed  by  this  Court  vide  its  order  dated  14.10.2019,  shall

continue to be in operation; and f) The amount of Rs.495,24,73,287/- deposited towards payment of

tax and the amount of Rs.2806,40,15,294/- which stands deposited

and invested in the form of Fixed Deposit Receipts shall be subject

to the decision to be taken by the concerned Authority on merits or

to such directions as may be issued by the Appellate Authority.

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19. We  have  stated  the  facts  of  the  present  case  only  by  way  of

narration of events and explaining the chronology.  We shall not be taken to

have dealt with merits or demerits of the rival contentions of the parties.

The merits of the matter shall be gone into independently by the concerned

authorities without being influenced, in any way, by any of the observations

made by the High Court and this Court.

20. The Appeal is disposed of in aforesaid terms and the judgment and

order presently under appeal shall stand modified accordingly. No costs.   

.......................................J.      [UDAY UMESH LALIT]

.......................................J.      [INDU MALHOTRA]

.......................................J.      [HEMANT GUPTA]

New Delhi; March 04, 2020.