Dish TV India Ltd. v. Commissioner of Trade and Taxes, Delhi

Delhi High Court · 13 Oct 2022 · 2022:DHC:4483-DB
Rajiv Shakdher; Tara Vitasta Ganju
VAT Appeal 34/2022
2022:DHC:4483-DB
tax appeal_dismissed Significant

AI Summary

The Delhi High Court held that the VAT Appellate Tribunal must comply with mandatory procedural safeguards under Section 76(8) before remanding assessments and allowed the appellant to withdraw the appeal to seek review on this issue.

Full Text
Translation output
NEUTRAL CITATION NO : 2022/DHC/004483
VAT APPEAL 34/2022
HIGH COURT OF DELHI
Date of Decision: 13.10.2022
VAT APPEAL 34/2022
DISH TV INDIA LTD. THROUGH ITS AUTHORIZED REPRESENTATIVE ..... Appellant
Through: Mr Vivek Sarin, Adv.
VERSUS
COMMISSIONER OF TRADE AND TAXES, DELHI..... Respondent
Through: Mr Satyakam, ASC.
CORAM:
HON'BLE MR JUSTICE RAJIV SHAKDHER
HON'BLE MS JUSTICE TARA VITASTA GANJU [Physical Hearing/Hybrid Hearing (as per request)]
RAJIV SHAKDHER, J.: (ORAL)
CM Appl. 44396/2022
JUDGMENT

1. Allowed, subject to just exceptions. CM Appl. 44397/2022

2. This is an application seeking condonation of delay in re-filing the appeal. The delay involved is 12 days.

2.1. Mr Satykam, who appears on behalf of the respondent, does not oppose the prayer made in the application.

3. The delay is accordingly condoned.

4. The application is disposed of in the aforesaid terms.

5. This appeal is directed against order dated 02.06.2022 passed by the Delhi Value Added Tax Appellate Tribunal [in short, “Tribunal”]. 5.[1] The operative directions are contained in paragraph 25 of the said order, which reads as follows:

“25. As a result, all these appeals are disposed of and the impugned assessments and the impugned orders as regards levy of tax, interest and penalty, based on the ground of suppression of sale and keeping in view the provision of Section 40A of DVAT Act are set-aside. However, in the given facts and circumstances and to save any loss to the exchequer by way of tax advantage on account of non-refund of input tax credit, due to sale of the set of product at a price lower than the actual purchase price, Assessing Authority shall be at liberty to proceed in accordance with law within the stipulated period from the date of communication of present decision, no doubt, after providing reasonable opportunity of being heard, to the dealer. ”

6. Mr Vivek Sarin, who appears on behalf of the appellant, says that although the appellant is not aggrieved by the directions contained in the aforementioned order whereby the impugned assessments and the orders concerning levy of tax, interest and penalty were set aside, what the appellant is aggrieved by is the direction issued in the very same paragraph which empowers the Assessing Authority to ascertain as to whether any loss has been incurred by the exchequer by way of tax advantage on account of non-refund input tax credit, due to sale of the product at prices lower than the actual price.

7. Mr Sarin says that the remand, if made, had to adhere to the conditions set forth in Section 76(8) of the Delhi Value Added Tax Act, 2004 [hereinafter referred to as the “Act”]. For the sake of convenience, the said provision is extracted hereafter:

“76. Appeals to the Appellate Tribunal
xxx xxx xxx
(8) The Appellate Tribunal shall not set aside an assessment
and remit the matter to the Commissioner for a further
assessment, unless it has first –
(a) advised the aggrieved person of the proposed order;
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(b) offered the person the opportunity to adduce such further evidence before it as might assist the Appellate Tribunal to reach a final determination.”

8. Mr Sarin says that the appellant was not advised by the Tribunal that it intended to set aside the assessment and thereafter, remit the matter to the Assessing Authority for further assessment.

9. We have no material on record to conclude that the submission made in this behalf by Mr Sarin is correct. According to us, the appellant should have, in these circumstances, immediately moved the Tribunal by way of a review application.

10. It is conceded by Mr Sarin that the Tribunal has powers of review, as reflected in Section 76(13) of the Act. 10.[1] Mr Sarin says that he wishes to withdraw the appeal and move the Tribunal by way of a review application, if liberty is granted in that behalf.

11. Mr Satyakam, who appears on behalf of the respondent, says that he cannot come in the way of the appellant moving the Tribunal by moving a review application.

12. The appeal is, accordingly, dismissed as withdrawn with liberty as prayed for.

12.1. The pending application shall stand closed.

13. The Tribunal will entertain the review application and rule as to whether the necessary ingredients of remand, as provided under Section 76(8) of the Act were fulfilled in the case.

14. Needless to add, nothing stated hereinabove would be construed as an expression of opinion as to how the review application should be dealt with and disposed of by the Tribunal.

(RAJIV SHAKDHER) JUDGE (TARA VITASTA GANJU)

JUDGE OCTOBER 13, 2022