Sutlej Cotton Mills Ltd v. Commr. Of Income Tax, West Bengal, Calcutta

SUTLEJ COTTON MILLS LTD. COMMR. OF INCOME TAX, WEST BENGAL, CALCUTTA September 27, 1978 [P. N. BHAGWATI AND V. D. TULZAPURKAR, JJ.] Income Tax Act, 1922-Secs. 10(1), 10(2)-Loss occasioned on account' of devaluation-Whether deductible as revenue expenditure-Circulating capi-tal and fixed capital. The assessee is a Limited Company having its Head Office in Calcutta~ It has inter alia a Cotton !\fill situated in West Pakistan where it carries on business of manufacturing and selling cotton fabrics. For the-accounting year relevant to the assessment year 1954-55, the assessee made a large profit in the unit in \\-'est Pakistan. The Pakistan profit, according to the official rate of exchange, which was then prevalent, namely, 100 Pakistani rupees being equal to 144 Indian rupees amounted to Rs. 1,68,97,232 in terms of Indian rupees. Since the assessee was taxed on accrual basis, the sum of Rs. 1,68,97,232 representing the Pakistani profit was included in the total income of the 'assessee for the assessment year 19"54-55\. and the assessee was taxed accordingly after giving double taxation relief in accordance with the bilateral agreement between India and Pakistan. On 8th August, 1955, the Pakistani rupee was devalued and parity between Indian and Pakistani rupee was restored. The assessee thereafter succeeded in obtain-ing the permission of the Reserve Bank of Pakistan to remit a sum of Rs. 25 lakhs in Pakistani rupees out of the Pakistani profit for the assessment year 1954-55. The profit of Rs. 25 lakhs in terms of Pakistani rupees had been included in the total income of the assessee for the assessment year 1954-55 as Rs. 36 lakhs in terms of Indian rupees according to the then prevailing rate of exchange !and, therefore, when the assessee received the sum of Rs. 25 lakhs on remittance of the profit of Rs. 25 lakhs in Pakistani rupees during the assessment years 1957-58, the assessee suffered a loss of Rs. t 1 lakh<i, in the process of conversion on account of appreciation of the Indian rupee qua Pakistani rupee. Likewise, in the assessment year 1959-60, a further sum of Rs. 12,50,000 was remitted by the assesse to India out of the Pakistani profit for the assessment year 1954-55 and suffered a loss of Rs. 5,50,000. The· assessee claimed in its assessment for the year 1957-58 and 1959-60 that these losses of Rs. 11 lakhs and Rs. 5,50,0-00 should be allowed in computing the· profit from business. The Income Tax Officer and the Tribunal disallowed the claim. On a reference to the High Court, the High Court took the view that no loss was snstain::.d by the assessee on remittance of the amounts from West Pakistan and that in any event, the loss could not be said to be a business Joss because it \.Vas not a loss ·arising in the course of business of the assessee but it was caused by devaluation which was an act of State. The High Court accordingly answered the question in favour of the Revenue and against the assessee. Disposing of the appeals by special leave the Court, 9 |Rataaaa mien fees fafedsOei).PonMaat aaa, RAR TT(M/s. Sutlej Cotton Mills Limited The Commissioner-of Income Tax, West Bengal).7(27 faaeax, 1978).|ne —etvsay genm dan tae, 1922 (1922 wm 11)—,uret10(1). ate(2) -arearet atag—trotteet atOitmaaore stare gtr —anit ar area a Pasieror—-aitHat Reeeoae eA ate eriy—iat:ata seer cet eat eoareerdt eta grit wate: feast|amt frattedt art wer ae aera eomnice anter &eTawa aEot amt ae ea et ae eGwa wave Paar & oY ofeadt oboea fers & wet fa ag aetear ae Tet car careare wed fo ae daecrer faa oHaeH, wt Per frefor ay 1954-55erat are Wa at ee 31 art, 1954 wt ware att ara Pasirar were aer-av or,Paaitedt + ae uae & aga afters arr waar ati ee Ey awe ame frattedt at oferdtt ofan a ster gar ar aixfataray at arate at am aaa, wt fa sa amr setae of,FTEata UR aeA 100 aT wat wredT & area TA 144F rare wat 1,68,97,232 & anaee aS wre.28Mo fLaw/79-2:—-.oo oy. faattet ox axe areafaa arr % arate ATTA WaT aTafer aedt of, fauferaf 1954-55 & fav fratfetd at =rary H anfaa ane at 7e at ate Proifedt ox eqare Ae TTSaatae at Prathedt a Prafey ae 1957-58& wend AaTao a ciwee F 25 are eae ofawoA SET HUTciaraart am % # 12,50,000wry at ofa whetart ora at wg cae ured wrai eoaereTe aaa aT. ee& fonfaettat aa amrdt aH an # whe oe TPR HTTemer gt & ayant oe oraseat FF 25 are orcae RNa Hye aT waa. afew gt svat ah aren Tae aeaferpeat %# 12,50,000 1] ave aye sae at atta # ant sary & way oer He1 set ara ware oe cifa Preherecet1957-58 wx 1959-60 a fan aud feuteol a ag arer caarfe sre greene & alt ara ara at aaT wed aT 1) arewz 5,50,000 eae at at atfaat ar are Pear art aries|grace afert tome aat arte ae Peati Peottedt # eeand & aterm# awe atrer At Par afewa oft ge aacSoothe at too oe Paw am fata F ahrasa Pater cat wate at we at ate aherey A See eaTaT aT Ua Ss feeae seq Pre fare farar or fee gar areataaout aie ofefeeteshat are # we ae ofa& ont & Pato at aaa fetesat fatrayatta an arat eld & erHie age at1 Petaat oferat cfaeam a caat eh Paseo oe aig apy adh aor?cetat ote Prat at er ove aha at areas Ht aha we eetvt wat |oaaife ae Pratfedt ho areata waeHF gi art‘qutcat fuer Peafer oft1 gen eravay a ae Sar Ee catSat Uses Paury ch ger A ate Prethedt & faeee featigayvraag& fava a fees Geren eaveH atte at oh atutratter—fraifedtat fester at 1954-55#garatTee wa ofet ofeee Fo ofeaeacet +Zt COT aT, «Tat we aeraa tH OuA ee OTeeaieadsy at sforat Ho 11 are wt ate 5,50,000 ma auTfza faecal wat bh aes H afereay oF wareaT ehRH steTé, ca Prat ar aeet a aofeade ox oat are ot ate atTIT Sl, GH zat a euraifen aw at aha ahh weffessartaF amg Te ate Cet aurwe er F fer aztTere afte ged atx faeet wer oerre afer at feae ce =(ft 3, 10)| Section: CONCLUSION HELD : The· first question that arises is whether the assessee sutfered any Joss on the remittance of Rs. 25 lakhs and Rs. 12,50,000. These 1wo .amounts admittedly came out of the Pakistani profit for the assel!Slllent year 1954-55, and the equivalent of these two amounts in Indian currency, namely, Rs. 36 lakhs and Rs. 18 lakhs respectively was included in the assessment of the assessee as part of Pakistani profit but by the time these amounts came to be repatriated to India, the rate of exchange had undergone change on .account of devaluation of Pakistani rupee and, threfore, on repatriation, the assessee received only Rs. 25 lakhs and Rs. 12.50 lakhs in Indian currency ·instead of Rs. 36 lakhs and Rs. 18 lakhs. The assessee thus suffered a loss of Rs. 11 Jakhs in one case and Rs. 5.50 lakhs in the other case; The fact thatl no Joss was reflected in the books of the two accounts of the assessee was not a conclusive factor and the High Court ought not to have reli~ on it It is now well-settled that the way in which entries are made by an assessee in his books of account is not determinative of the question whether the asse-Ssee has earned any profit or suffered any los~. [981 A-D, 982 A-B CJ Conunissio11er of Income Tax v. Tata Loco1notive EngineeTing Co., 60 I. T.R. 405 relied on. The question arising ~n the case is whether the loss sustained by the asses-t1ee :was a trading loss and if it was a trading loss whether it would be liable to be deducted in computing the taxable profit of the assessee under Sec. 10(1) -of the Income Tax Act, 1922. The argument which found favour with the High Court was that because the devaluation was an act of the sovereign power. it could not be regarded as a 10&s arising i.n the cour5e of the business of the assessee or incidental, to such business, is plainly erroneous. It is true 1hat a loss in order to be a trading loss must spring directly from the carrying on of business ior be incidental to it, but it would not be correct to say that where a loss arises in the process of conversion of foreign currency which is part of trading asset of the assessee, such loss cannot be regarded as a trading loss because the change in the rate of exchange which occasions such loss is due to an act of the sovereign power. [982 D-G] Badri Das Dada v. C.l.T., 34 J.T.R., 10 relied on. It is not the· factor or circumstance which caused the l06s that is material in determining the true nature and character of the toss, but whether the loss has occurred in the course of carrying on the business or is incidental to it. If there is a loss in trading asset, it would be a trading loss, whatever be its cause, because it wolild be a loss in the coursei of .carrying on the businefitl. If the stock in trade of a business is stolen or burnt the loss, though occasioned by external agency or act of God would clearly be a trading loss. Whether the loss sufi'ered by the assessee is a trading loss or not, would depend on the answer to the query whether the loss is in respect of a trading asset or a capital asset. In the former case, it would be a trading loss but not So in the latter. The test may be formulated in another way by asking the question whether .the loss is in respect of circulating capital or in respect of fixed Capi-tal. It 1s, of course, not easy to define precisely what is the line of demarca-ti~n. be~ween fixed capital and circulating capital but there is a well recognised distinction between the two concepts. Adam S1nith in his 'Wealth of Nations' describes fixed capital as what the owner turns to profit by keeping it in hls 978 SUPREME COURT REPORTS acea alyFal~SUTUTaCah aa. alt~~LS}Paw Te FSat as Psx.aE—_ ATT. FH™. WATT WA~s FT“.ted: Tey FE El UT US~ BSTT FeEassaa=y»>aye, agenceSta,‘ atefotoNLncakes=.rae©rnacSpeSheet5facet wea wh auf<edeapt whepur FFe.we ei. az! Cal. aiaay!mopeerer2ETITT Pere Ts. quis oor Per det crortme RAToe oewo GHeTseefF=aayPATHwees TRTAHSPLoooyeGrms. et sa~[reet eeap eeeeEEeeeaope~eS.osFIST SatN¥ &=>=| ee~r Bildfas HTrt‘. Satn ITEpoeh (oT Reh eidrta siat. Abom RN @ TesesaweCRG FS See ayy aS Are ocr ateait BAG wits BRIN 3S eee ae ec Sid arr Gt& le mst Mmray— na! wet SetMoteweyfie cor seek oormeerfies apr oe &meerseemptCeGay Byspempye te ore SS Bere aprrraare at oo ofser oatetaait =Th SAT FE RA ATMS HEAth SAHHOee | eb eumrae <4 eet“yy“,seesn. mT Th heeeAarene oresasf7soemrd2-55memeeg pekeeGo.gheeEeweeepeeopny cee ceeee oteokeee iseoopeepmee oowe Gepereeee cenSe oyBee agefee eeechee rereoeoneymsonSr?PaesLSS~, reie%copyoS*gSPop met~Oe eyeYe mw“ pyre‘ i Ivar.Be =ist—wegehenye RaeReanf eee peerc= wk=) <g> >ee meee meeeSeoeore geeerfe Se cee pee Pee Get ogfer ae eeooPereerur5To — —te weerees = ~TSOng?veeerenz+.=ort y£—~ =rPan oe setsspacer ier owiscrSaynarbaares7Pras serra oe Pa oneAree.HT Blin SS= BTSe aE~ Heteei™~ EN| SaTRIGh Sipeser atesee epee ey eootinpa1weit epeewephcgePere eh PeeaaeeeGheeepeeopemereA eeeComey~epepesepertiSe eaeckapo efyirceereePeee GS spreap TS erpefetb" Bla ayy & ZopeTa urgeSR tebe mcreryrar gb teh Alls airmiesrrfecheers an fefarrTara poyat eyrawUP eeay oa ce onprocnr eyfeurySayerstUST onesCATsveraswrEPA aycafe gre gerop gee qedwooafe Peas opsetyaoanywaeHiteTTmeee w SMHSpeersDNeeYTpre saggycemeperefeper yay Waryoneyeeeraea: Geereir Oyae Sheetepee SPpepe &one-receetyoP Serep peeceee of matt Boo Fore clkoe_.,‘2+ fotergy =Seppogemenieemp_—=é=.t=weegeF~. Fra A~ Fyfr. ali Catt. Pearch rate 2 zita; Paedfz—_~ieOrsqe HSvee cathe etherSermperBY FoHH ofesGIS F& aTH oseMa MAGS aqaww AMN SOR vereaA~ ariry aftafe correr es. arty zhi.fyi(ter 4)fim faiaa atiat afaariza: 1972 a fafas wie Meat 1847-18481966S aaae fin tem 128 F wares get ATTA Fava 30 44a, 1970 aa fata aie ara F fees we ATT |shat BY ATTa||—-ggay dtoHIT, THo ATLo wae ATATA, WIXo Zang, fro ate T7eqatar, to eto Gai ae TaTT soudt at atea scdiarat Ht ate aAto Fro Gaiaseat at att aHATS To TATAT amrarae at Pavia eorotfasfat- or. wada fear} fagy gradSat ao adit HaHa Sy MATTH VEtess & fang ft ve f foe art afenen ar va falecom pee ar wax were ova Fate freffedta Prege fotoo wer Ho 2H 5 aw ae ae|W ATS A ys ata FATmex Seat l ww gt ofeeitad 21 ae He BT THT AT Cgey mma & aedt ate ofeteaat earaat #at fautey af 1957-58«#Pau11 are wT atfafaue ata ar tet wie freien at 1959-60 % fee550,000 eat at fatana ata ar arat Fete & ETactin 2faefey aurat aaaSat Vergatzatayat he at ahi, Pert a sate frefeo ad at area che, Potcope eto. ee detg wo eee afula wet aathesEy er aT 978 own possession and circulating capital as what he makes profit of by parting with it and lettinii in change masters. Circulating capital means capital employed in the trading operations of the business and the dealings with it comprise trading receipts and trading disbursements, while 'fixed capital' means capital not 10 employed in the business, though it may be used for tho purposes of a manufacturing business but does not constitute capital employed in the trading operations of the business. [982 H, 983 A·F] Golden Horse Shoe (neu') Ltd. v. Thurgood, 18 T.C. 280; approved. Landes Bros. v. Sinipson, 19 T.C .. 65; Davis v. Shell .& Co. of Chine_ Ltd .• 32 T.C. 133; Imperial Tobacco Co. v. Kelly; 25 T.C. 292; referred to with approval. Commr. of lncome·tax. Bon1bay City v. Tata Locon1otive & Engineering c Co. Ltd., 34 l.T.R. 10 approved. Commr. of lncon1e·tax, Mysore v. Canarti Bank Ltd., 63 I.T.R. 308 approved. It \is clear from the authorities that where profit or loss arises to an assessee on account of appreciation or depreciation in the value of foreign D currency held by it, on conversion into another currency, such profit or loss would ordinarily be trading profit or loss if the foreign currency is held by the essesse on Revenue account or as a trading asset or as part of circulating capital embarked in the business. But if, on the other hand, the foreign cur~ rency is held as a capital asset or as fixed capital, such profit or loss )WOuld be of capital nature. [991 B-CJ E In the present case, no finding has been given by the Tribunal as to whether the sum of Rs. 25 lakhs and Rs. 12.50 lakhs were held by the asses-see in West Pakistan on capital account or Revenue account and whether they were a part of fixed capital or of c:rculating capital embarked and adventured in the business in West Pakistan. If these two amounts were employed in the business in West Pakistan and formed part of the circulating capital of that business. the loss of Rs. 11 lakhs and Rs. 5.50 lakhs resulting F to the assessee on remission of these two amounts on account of alterations in the rate of exchange, would be a trading loss, but if instead these two amounts were held on capital account and mere part of fixed capital the loss would plainly be a capital loss. [991 C-EJ The Court was, therefore, unable to answer the question whether the loss suffered by the assessee was a trading l~s or a capital loss. Ordinarily, the Court would have called for a supplementary statement of the case, fro-m the Tribunal but since both the parties. agreed that it would be proper that the matter should go back to the Tribunal with a direction to the Tribunal either to take additional evidence itself or to direct the Income Tax Officer to take additional evidence and make a report, the Court made an order accordingly and directed the tribunal to dispose of the case on the basis of th-e additional evidence and in the light of the law laid down in the Judgment. [991 E-HJ ClvIL APPELLATE JURISDICTION : Civil Appeal Nos. 1847-\848/72. From the Judgment and Order dated 30-4-1970 of the Calcutta High Court in Income Tax Reference No. 128 of 1966. V. S. Desai, P. V. Kapur, s. R. Agarwal, R. N. Bajoria, A. T. Patra and Pravee11 Kumllr for the Appellant. J. Ramamurthy and Miss A. Suhbashini for the Respondent. The Judgment of the Court was delivered by BHAGWATI, J.-These appeals by special leave are directed against a judgment of the Calcutta High Court answering the first question referred to it by the Tribunal in favour of the Revenue and against the assessee. There were in all five questions referred by the Tribunal but questions Nos. 2 to 5 no longer survive and these appeals are limited only to question No. l. That question is in the following terms:- 2. fraifedt wafufate ae g foe yeasciara a fore & wer fa ag atl SIs aad AIR a erareart wedt 21 we carrera Paw wen are Sere ware oft oeae 1954-55 ar adaa weray at,faaffedt tarwan aage wfeen arr Hara aTereeTae ae Prete arqreait obacom aH ster gar a ate fateae at areratr ax& omar, wt fa se ay seta ot, war absent 4 106wai h urd # 144 erat F Aes Fa H HT IT ZT,fad efaer & Pau ofa ater arr mer HT BHAT Ss, VIRATAae & HT 1,68,97,232 wat ayi Prelfedtve ae areaae 1954-55 a fou Paathedh at aa ate wo oattyea ae aT 1gfai frie ox,ame ee ofa& arefer afgrela we Ho ara Tea ae Wet AHTeaTSL TALEa aferdfuafot wat at1 ue secede & fe are & Paarare awe are we ure ateooifeea ae drefafeau zeesuratwet ot Parr 18 faareax,1949at arte wasgqqvaaoe fafron at av ofeafae at we at Pere ore100 ofaraet wow arer 144 waa & aeray at me a ATfaviey ay 1954-55 & fau fraitedt at aq ay H ant &atee far aa & sdtwaret ofaecar avat amr set fataaa 2zoy wredia saat aufeatda Peat wet ati aarfa, Pafraeatone aa wo wee ghar ate ee sa a aoe FH Prelfect+ frafor av 1957-58 &weve gerat ashor wre & «=» [1979] 4 BH[Ho To 95 are wre ofaatt ae wet. eae ati Preffedt 4trutcy at 1959-60& aaaaser at aw ater ofaartamy % 4 12,50,000 ere at uta oifaeartt erat Haat Haataf ait ae ule Prater at 1954-55 a Pau Port aes areqifearatar aT ARH TAT ITT HA eh TSAI Bt WAT BUTE TEft. Parr wa am at fatern Pag ae, cat ha are mer TAT¢, Pateraax Tom are fox chadsat water fret facifeca& 100 wrt ara& 100 erat @ aaae at at meaaare sett et, wala, 25 are aay ate 12,50.000 wayattfauftr at 1954-55 & fau Praffedt at ae ata wt arr a aieut ofaearl aca 7 25 are seat at ufe aaayafafana ax aqufa: ofa& 100 erat & uredtr 144 wai &ware gt & ares ox uredia ataAT 36 wre wae at ute aafencartter ¥ afeafad at we tt ate gata wa frelfedtt 100uta ewirat & HF 100 25 wreita are eaerat eh Aart & qarer STAT att AMI H aay ATA TeOTTaredte aaa & rare 25 are wae at uta at sree at aa Pratheatat uredBau th Awe aw oerBIT H Tey Al aA A aTat ara & carey aateadat ahrfat A 11 are ere at aha sarief1 get sare ofaeart weet H 12,50,000 we & amrB FAT HUTT aA Te Prafhedt at 5, 50,000 wrt at att soritcet«| Praffedt & Prater af 1957-58 ate 1959-60 & fazataut Pratoa ag erat Par fe sae areare & alt ard wailar erat we Pear axed wae art 11 ar afre ate1 5,50,anita000 ae wryat aafvar atratHug wat aaaae fear PaaffhedtA ee are F aPerneyott ar veel foro aie atte anderaeet 1Prefectatwé oft ate aferA ver deat 1, at fa are orate featwaz, ser raravay at we & Pau faefarr foro at1 faeer far aPe ea a we,sel we eTaTaT aT Escesar fara& taal a Pare oe ate ate wet gory ostay ate Peat at aera ve aha al sreare at gite Aer Hetwaar eaifae ag Prothect & areare @ aA A att are? aewat ot Pret ag aaarar & aren ge at wt fa tH mea Peereva t ate Pratl# foes Peariagate fefadt 4 ser 3. Prarey sey seq oe gerrs altar @ far gar Tee ceta ofeadt ofa4 oPeerdtset a 25 are ee wit12,,50,000& faxuoy ox aig-ate ge1 wee ey a 4ata wee Prater at 1954-55 & Paw ofaeaart art aort ge at aie arate MCS A ee al CHASH aHee ta aSqe FH aTH Tea, TRIVT B AaNHUH B aToTfarang act oofmada at rea a ak gafaw oarY cy esgery eae 25 are #17 12,50,OOO wa ume gayiowsare Pratfedt al oaratedtt a uredia ated? # eefeadtay ofa a, we ane WL] are ere ate gee5,50, 000wa ft gtr eget.Paeregag sagaey Tetfe aefo, acaua saa Pafrna ar ax a aware ered weetai vic aét wre feater at 1954-55# au faethe= "Whether on the facts and in the circumstances of the case, the assessee's claim for the exchange loss of Rs. 11 lakhs for the assessment year 1957-58 and Rs. 5,50,000/-for the assessment year 1959-60 .in respect of remittances of profit from Pakistan was not allowable as a deduction? Since there are two assessment years in regard to which the question arises, there are two appeals. one in respect of each assessment year, but the question is the same. W will briefly state the facts as that is necessary for the purpose of answering the question. The assessee is a limited company having its head office in Calcutta. It has inter alia a cotton mill situate in West Pakistan where it carries on business of manufacturing and selling cotton fabrics. This textile mill was quite a. prosperous unit and in the financial year ending 31st March, 1954, being the accounting year relevant to the assessment year 1954-55, the assessee made a large profit in this unit. This profit obviously accrued to the assessee in West Pakistan and according to the official rate of exchange which was then pre-valent, namely, 100 Pakistani rupees being equal to 144 Indian rupees, this profit, which may for the sake of convenience be referred to as Pakistan profit, amounted to Rs. 1,68,97,232/- in terms of Indian rupees. Since the assessee was taxed on actual basis, the sum of Rs. I ,68,97,232/- representing the Pakistani profit was included in the total income of the assessee for the assessment year 1954-55 and the assessee was taxed accordingly after giving double taxation relief in accordance with the bilateral agreement between India 'and Pakistan. 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