Partly allowed

A C T O Jaipur v. M/S Anil Agencies Pvt. Ltd.

Rajasthan HC23 Sept 2016STR/43/2012

Case brief

AI extract

What is this about?

A tax revision petition challenging the quashing of penalty imposed for transporting goods with an incomplete VAT declaration form. The High Court held that blank particulars and failure to punch mandatory fields constitute substantive non-compliance, not technical errors, affirming the penalty.

What did the court decide?

The impugned order of the Tax Board allowing the appeal was reversed; the order of the Assessing Officer and Deputy Commissioner of Appeals upholding the penalty was restored.

A C T O Jaipur Vs M/S Anil Agencies Pvt. Ltd. — Cheque Dishonour | Rajasthan HC (2016)

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IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN AT JAIPUR BENCH, JAIPUR

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S.B. Sales Tax Revision Petition No.43/2012 ACTO, FLYING SQUAD-VI, RAJASTHAN, JAIPUR

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M/S. ANIL AGENCIES PVT. LTD., TRANSPORT HOUSE, RAILWAY STATION, IN FRONT OF JHOTWARA, JAIPUR

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Order reserved on : 7^th September 2016 Order pronounced on : 23^rd September 2016

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HON'BLE MR. JUSTICE JAINENDRA KUMAR RANKA

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MS. MEENAL GHIYA counsel for petitioner MR. SARVESH JAIN counsel for respondent

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ORDER -----

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The instant petition is directed against order dated 27.6.2011 passed by the Rajasthan Tax Board, Ajmer, in Appeal No.2324/2008/Jaipur, by which appeal of the respondent has been allowed.

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The brief facts noticed are that on 26.12.2007, vehicle bearing no.RJ-32G-2087 was intercepted at Jaipur. The driver/in-charge produced builty no.161687, delivery note nos.3529 & 3530, bill nos.7484 & 7485, and declaration form VAT 47 bearing no.2167789. On perusal of the VAT 47, it was noticed by the Anti Evasion Wing that various columns were found blank/not filled in, namely column no.3 of partA, column nos.1-4 of part-B, and column no.2 of part-C, and it transpired that nature of transaction, invoice/bill/no. on despatch memo, date, value, description of the goods, builty no. etc. were found blank. So also it was noticed that VAT 47, insofar as

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date, month and value are concerned, was not duly punched and, therefore, it was prima facie noticed by the officer that it was with the intention of evasion of tax. It was also noticed that the vehicle contained 202 bundles of paper-roll whereas the documents produced were for 185 bundles of paper. Accordingly show cause notice u/s 76(2)(b) of the Act was issued. On the show cause notice, on behalf of the respondent assessee, in the light of judgment of apex court in the case of State of Rajasthan & Another v. D.P. Metals (2001) 124 STC 611, VAT declaration form 47 duly filled was produced and it was claimed by the assessee that the assessee complied with the provisions of the Act and accordingly no penalty is required to be levied. However, the officer was not satisfied and rejected the contention by holding that the declaration form ought to have been completely filled in all respect and also to be punched simultaneously, accordingly levied penalty u/s 76(6) of the Act.

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The matter was assailed before the Dy. Com. (Appeals) who took into consideration the material placed on record and held that the judgment in the case of D.P. Metals (supra) is not applicable and also held that in the light of judgment in the case of Guljag Industries vs CTO, ( 2007) 7 SCC 269, the penalty was rightly imposed and the goods were transported with the intention of evasion of tax. On a further appeal by the assessee before the Tax Board, resulted into allowing of the appeal, particularly by the Tax Board

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by holding that the production of subsequent VAT 47 on a show cause notice was justified and taking into consideration the judgment of D.P. Metals (supra), was sufficient compliance hence deleted, however, since the assessee produced declaration form only with reference to 185 bundles, therefore, for the balance there being no declaration form, penalty was sustained.

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Learned counsel for the Revenue vehemently contended that the order of Tax Board is perverse and is required to be interfered with, particularly in view of the fact that both the AO as well as Dy. Com. (Appeals) found as a finding of fact that the material particulars were found left blank and it clearly proved that the goods were being transported with the intention of evasion of tax. Learned counsel further contended that merely producing another declaration form is of no avail for compliance of the mandate of law is required to be fulfilled. Rule 53 mandates that there should be sufficient compliance in letter and spirit and such declaration form should have been carried and ought to have been produced at the time of interception of the vehicle. She further contended that even otherwise the subsequent declaration form, if also considered, then too it is defective as both, AO as well as the Dy. Com. (Appeals) have held that it was not punched and this was an additional feature of punching the declaration form, as the Revenue felt that assessees are involving in carrying declaration forms with the intention of evasion of tax, though before the

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Tax Board specifically this claim was raised by the authorised representative that the declaration form is not punched, however, the Tax Board has conveniently ignored this material aspect and thus contended that in the light of the judgment in the case of Guljag Industries (supra), the penalty was rightly imposed and wrongly deleted by the Tax Board.

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Per contra, learned counsel for the assessee contended that the imposition of penalty was not proper and the Tax Board had rightly deleted the same. He further contended that subsequent filing of the declaration form is sufficient compliance as in the first instance on a show cause a new declaration form was given duly filled in, complete in all respect, and in the light of the judgment in the case of D.P. Metals (supra) penalty was rightly deleted by the Tax Board. He further contended that when the new declaration form duly filled in has been placed on record, then the judgment of Guljag Industries (supra) is not applicable and distinguishable. He also contended that punching of a document is a technical error and ought not to be made a basis for imposition of penalty. He also relied upon the judgments rendered in the case of ACTO v. M/s S. Vrindavan Oil Products , 2006 (Part 3) Tax Up-Date (15) page 109; CTO v. M/s. Globe Transport Corporation , S.B. STR No.165/2011 decided on 26.2.2013; ACTO v. M/s. REBI Casting (Pvt.) Ltd. S.B. STR No.400/2008 decided on 1.8.2013; ACTO V. M/s. Suresh Kumar & Company S.B. STR No.105/2010 decided on 30.5.2013; ACTO, Jaipur v.

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M/s. Dueful Laboratories, Jaipur , S.B. STR No.542/2011 decided on 29.8.2016.

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I have considered the arguments advanced by the learned counsel for the parties and perused the impugned order.

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It would be appropriate to quote Sec.76 of the VAT Act as well as Rule 53 of the VAT Rules which read ad-infra:-

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Sec. 76 of VAT Act :

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“76. Establishment of check-post or barrier and inspection of goods while in movement

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(1) The Commissioner may, with a view to prevent or check avoidance or evasion of tax, by notification in the Official Gazette, direct the setting up of a check-post or the erection of barrier or both, at such places as may be specified in the notification, and every officer or official who exercises his powers and discharges his duties at such check-post or barrier by way of inspection of documents produced and goods being moved shall be its Incharge.

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(2) The owner or a person duly authorised by such owner or the driver or the person Incharge of a vehicle or carrier or of goods in movement shall-

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(a) Stop the vehicle or carrier at every checkpost or barrier, and while entering and leaving the limits of the State bring and stop the vehicle at the nearest check-post or barrier, set-up under sub-section (1);

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(b) carry with him a goods vehicle record including “challans” and “bilties”, invoices, prescribed declaration forms and bills of sale or dispatch memos;

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(c) produce all the documents including prescribed declaration forms relating to the goods before the Incharge of the check-post or barrier;

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(d) furnish all the information in his possession relating to the goods; and

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(e) allow the inspection of the goods by the Incharge of the check-post or barrier or any other person authorised by such Incharge.

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Explanation: For the purpose of this Chapter ‘goods in movement’ shall mean-

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(i) the goods which are in the possession or control of a transporting agency or person or other such bailee;

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(ii) the goods which are being carried in a vehicle or carrier belonging to the owner of such

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goods; and

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(iii) the goods which are being carried by a person.

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(3) The State Government may require by notification that the documents required to be furnished under sub-section (2), shall be furnished by means of such electronic devices, and be accompanied by such processing fee, as may be prescribed.

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(4) Where any goods are in movement within the territory of the State of Rajasthan, the assessing authority or an officer authorised by the Commissioner in this behalf may stop the vehicle or the carrier or the person carrying such goods, for inspection, at any place within his jurisdiction and the provisions of subsection (2) shall mutatis mutandis apply.

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(5) Where any goods in movement, other than exempted goods, are without documents, or are not supported by documents as referred to in subsection (2), or documents produced appears to be false or forged, the Incharge of the check-post or barrier or the officer authorised under subsection (4) may-

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(a) direct the owner or a person duly authorised by such owner or the driver or the person Incharge of the vehicle or carrier or of the goods not to part with the goods in any manner including by re-transporting or re-booking, till a verification is done or an enquiry is made, which shall not take more than seven days;

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(b) seize the goods for reasons to be recorded in writing and shall give a receipt of the goods to the person from whose possession or control they are seized;

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(c) release the goods seized under clause (b) to the owner of the goods or to a person duly authorised by such owner, during the course of the proceeding, if adequate security of the amount equal to the estimated value of the goods is furnished.

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(6) The Incharge of the check-post or barrier or the officer authorized under sub-section (4), after having given the owner of the goods or person duly authorised in writing by such owner or person Incharge of the goods, a reasonable opportunity of being heard and after having such enquiry as he may deem fit, shall impose on him for possession or movement of goods, whether seized or not, in violation of the provisions of clause (b) of sub-section (2) or for submission of false or forged documents or declaration, a penalty equal to thirty per cent of the value of such goods.”

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Rule 53 of the VAT Rules : 53. Declaration required to be carried with the goods in movement for import within the State.(1) A registered dealer,

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(i) who import from any place out side the State, any taxable goods, as may be notified by the State Government, for sale; or

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(ii) who receives any taxable goods as may be notified by the State Government, consigned to him from outside the State or by way of branch

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transfer/depot transfer/stock transfer; or (iii) who intends to bring, import or otherwise receives any taxable goods as may be notified by the State Government, from outside the State for use, consumption, or disposal otherwise than by way of sale;

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shall furnish or cause to be furnished a declaration in Form VAT-47, completely filled in all respect in ink and ensure that the value, date and month or use of such Form shall be punched at the specified place provided for in the Form. The counterfoil of the declaration Form shall be retained by such dealer and its portions marked as ‘Original’ and ‘Duplicate’ shall be carried with the goods in movement. However, where goods covered under single invoice are being carried in more than one vehicle, separate Form VAT-47 shall be accompanied with each of such vehicles along with photo copy of the original invoice and challan of the goods carried in the vehicle.

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[Provided that subject to such conditions as may be specified by the Commissioner, a registered dealer may also furnish a declaration in Form VAT-47A, electronically through the official web-site of the Commercial Taxes Department of the State.

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Provided further that a dealer may furnish the details of serial number of Form VAT-47, vehicle number, Invoice/Bill/Dispatch memo number with date and value of goods regarding the goods in movement either through Short Messaging Service (S.M.S.) or through Interactive Voice Response System (I.V.R.S.), to the department on the telephone numbers allotted for this purpose through a pre intimated cellular phone before the goods enter into the territory of the State. On intimation of the aforesaid information the dealer shall receive an Identification number through S.M.S. on same cellular phone. He shall also furnish or cause to be furnished the declaration Form VAT-47 completed in all respect to his assessing authority by the next working day. The owner or a person duly authorised by such owner or the driver or the person incharge of a vehicle or carrier or of goods in movement shall intimate the said Identification number to the assessing authority or the person authorised by the Commissioner at the time of checking of goods in movement, which shall be deemed to be prescribed form with goods in movement. (2) The owner or a person duly authorised by such owner or the driver or person Incharge of a vehicle or carrier or of goods, shall carry with him the documents specified in clause (b) of subsection (2) of section 76 including declaration form prescribed in sub-rule (1), in respect of the goods in movement and shall produce the same suo motu before the assessing authority or the officer authorized under sub-section (4) of section 76 at the time of inspection who shall retain the original portion of the declaration form and return the duplicate portion after signature and marking seal in token of having verified it, to person producing it and such

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officer shall send the retained original portion of the declaration form to the assessing authority or the authorized officer.

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(3) If the declaration Form referred to in subrule (1) in respect of the goods in movement has already been submitted to the assessing authority or the officer authorized under sub-section (4) of section 76, the owner or a person duly authorised by such owner or the driver or person Incharge of the vehicle or carrier or of the goods shall, on inspection by an officer authorized under sub-section (4) of section 76, at any subsequent place, produce the countersigned and sealed copy of the aforesaid declaration along with other documents specified in clause (b) of sub-section (2) of section 76. Explanation: For the purpose of this rule, ‘taxable goods’ means all goods except the goods which are exempted from tax in accordance with the provisions of the Act.”

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Section 76 of the VAT Act takes into consideration the movement of goods while in transit and it envisages that the owner, driver or incharge of the vehicle, which is carrying on certain goods, shall stop the vehicle or carrier at every check post or barrier while entering and leaving the limits of the State and such vehicle shall carry a goods vehicle record including challan, builties, invoices, prescribed declaration form and bills of sale and dispatch memos and other documents as envisaged in Sec. 76.

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Simultaneously, Rule 53 of the VAT Rules mandates that a declaration form is required to be carried with goods in movement for import within the State and the registered dealer shall furnish or cause to be furnished a declaration in Form VAT-47 completely filled in all respect in ink and ensure that the value, date and month of use of such Form shall be punched at the specified place provided for in the Form.

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On perusal of the facts, admittedly at the time of interception of the vehicle, the declaration form was found with the in-charge/driver, it was incomplete and number of columns were even left blank, which has already been noticed earlier. It may be on a show cause notice having been given, the assessee did produce another declaration form which is claimed to be filled in and complete in all respect. During the course of hearing, learned counsel for the assessee produced both the declaration forms and contended that the subsequent Form takes care of fulfilling the Declaration VAT 47.

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The matters relating to blank/incomplete declaration form has been the bone of contention in between the Revenue and the assessee in particular and earlier when the declaration forms were ST-18A, ST18AA, ST-18C, the matters travelled before the apex court and the apex court in the case of D.P. Metals (supra) held that carrying declaration form complete in all respect is mandatory, however, in case the declaration form was not found with the vehicle, the apex court held that if a show cause notice is given and a declaration form is produced at the first instance, then such a Form can be considered to be sufficient compliance. It was held ad infra :-

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“32. Such submission of false or forged documents or declaration at the check-post or even thereafter can safely be presumed to have been motivated by desire to mislead the authorities.

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Hiding the truth and tendering falsehood would per se show existence of mens rea, even if required. Similarly where, despite opportunity having been granted under Section 78(5) if the requisite documents referred to in clause (a) of sub-section (2) are not produced, even though the same should exist, would clearly prove the guilty intent. It is not possible to agree with the counsel for the respondents that breach referred to in Section 78(5) can be regarded as technical or venial. Once the ingredients of Section 78(5) are established, after giving a hearing and complying with the principles of natural justice, there is no discretion not to levy or levy lesser amount of penalty. If by mistake some of the documents are not readily available at the time of checking, principles of natural justice may require some opportunity being given to produce the same. This provision cannot be read as to imply that the penalty of 30% is the maximum and lesser penalty can be levied. The legislature thought it fit to specify a fixed rate of penalty and not give any discretion in lowering the rate of penalty. The penalty so fixed is meant to be a deterrent and we do not see anything wrong in this. The quantum of penalty under the circumstances enumerated in Section 78(5) cannot, in our opinion, be regarded as illegal. The legislature in its wisdom has thought it appropriate to fix it at 30% of the value of goods and it had the competence to so fix. As held by this Court in Rai Ramakrishna v. State of Bihar at SCR p 910:

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“The objects to be taxed so long as they happen to be within the legislative competence of the legislature can be taxed by the legislature according to the exigencies of its needs, because there can be no doubt that the State is entitled to raise revenue by taxation. The quantum of tax levied by the taxing statute, the conditions subject to which it is levied, the manner in which it is sought to be recovered, are all matters within the competence of the legislature, and in dealing with the contention raised by a citizen that the taxing statute contravenes Art.19, courts would naturally be circumspect and cautious.”

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as such there cannot, in the present case, be any valid challenge to the rate of penalty provided for in Section 78(5) of the Act.”

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In cases where declaration forms were incomplete or where material particulars were found to be not filled in/blank, the apex court in the case of Guljag Industries (supra) held that such declaration forms cannot be considered, and it would be appropriate to quote the relevant paras which read ad infra:-

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“25. There is dichotomy between contravention of Section 78(2) of the said Act which invites strict civil liability on the assessee and the evasion of tax. When a statement of import/export is not filed before the A.O. it results in evasion of tax, however, when the goods in movement are carried without the declaration Form No. 18A/18C then strict liability comes in, in the form of Section 78(5) of the said Act. Breach of Section 78(2) imposes strict liability under Section 78(5) because as stated above goods in movement cannot be carried without Form No. 18A/18C.

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We are not concerned with non-filing of statements before the A.O. We are concerned with the goods in movement being carried without supporting declaration forms. The object behind enactment of Section 78(5) which gives no discretion to the competent authority in the matter of quantum of penalty fixed at 30 per cent of the estimated value is to provide to the State a remedy for the loss of revenue. The object behind enactment of Section 78(5) is to emphasise loss of revenue and to provide a remedy for such loss. It is not the object of the said Section to punish the offender for having committed an economic offence and to deter him from committing such offences. The penalty imposed under the said Section 78(5) is a civil liability. Willful consignment is not an essential ingredient for attracting the civil liability as in the case of prosecution. Section 78(2) is a mandatory provision. If the declaration Form 18A/18C does not support the goods in movement because it is left blank then in that event Section 78(5) provides for imposition of monetary penalty for noncompliance.

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Default or failure to comply with Section 78(2) is the failure/default of statutory civil obligation and proceedings under Section 78(5) is neither criminal nor quasi-criminal in nature. The penalty is for statutory offence. therefore, there is no question of proving of intention or

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of mens rea as the same is excluded from the category of essential element for imposing penalty. Penalty under Section 78(5) is attracted as soon as there is contravention of statutory obligations. Intention of parties committing such violation is wholly irrelevant.

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Moreover, in the present case, we find that goods in movement carried with Form No. 18A/18C. The modus operandi adopted by the assessees itself indicates mens rea. This is not the case where goods in movement are carried without the declaration forms. In the present matter, as stated above, goods in movement were carried with the declaration forms. These forms were duly signed, however, material particulars were not filled in. The explanation given by the assessees in most of the cases is that they are not responsible for the misdeeds of the consignors. The other explanation given by the assessees is regarding the language problem. There is no merit in these defences. They are excuses. The declaration forms were unfilled so that they could be used again and again. The forms were collected by the consignee from the said Department. The consignee undertakes to see that the value of the goods is supplied by the consignor. It is not open to the consignee to keep the column in respect of the description of goods as blank. Even the column dealing with nature of transaction is left blank. The consignee is the buyer of the goods. He knows the descriptions of the goods which he is supposed to buy. There is no reason for leaving that column blank. therefore, there are no special circumstances in any case for waiver of penalty for contravention of Section 78(2). The assessees were fully aware that the goods in movement had to be supported by Form ST 18A/18C. therefore, they made the goods travelled with the forms. However, the said forms are left blank in all material respects. therefore, A.O. was right in drawing inference of mens rea against the assessees.

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It has been repeatedly argued before us that apart from the declaration forms the assessees possessed documentary evidence like invoice, books of accounts 14 etc. to support the movement of goods and, therefore, it was open to the assessees to show to the competent authority that there was no intention to evade the tax. We find no merit in this argument. Firstly, we are concerned with contravention of Section 78(2) which requires the goods in movement to travel with the declaration in Form 18A/18C duly filled in. It is Section 78(2)(a) which has been contravened in the present case by the assessees by carrying the goods with blank forms though signed by the consignee. In fact, the assessees resorted to the above modus operandi to hoodwink the competent officer at the check-post. As stated above, if the form is left incomplete and if the description of the goods is not given then it is impossible for the assessing officer to

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assess the taxable goods. Moreover, in the absence of value/price it is not possible for the A.O. to arrive at the taxable turnover as defined under Section 2(42) of the said Act. therefore, we have emphasized the words "material particulars" in the present case. It is not open to the assessees to contend that in certain cases of interstate transactions they were not liable in any event for being taxed under the RST Act 1994 and, therefore, penalty for contravention of Section 78(2) cannot be imposed. As stated hereinabove, declaration has to be given in Form 18A/18C even in respect of goods in movement under interstate sales. It is for contravention of Section 78(2) that penalty is attracted under Section 78(5). Whether the goods are put in movement under local sales, imports, exports or interstate transactions, they are goods in movement, therefore, they have to be supported by the requisite declaration. It is not open to the assessee to contravene and say that the goods were exempt. Without disclosing the nature of transaction it cannot be said that the transaction was exempt. In the present case, we are only concerned with the goods in movement not being supported by the requisite declaration.”

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Both the judgments have, however, held that if the declaration form is not found or/and found not filled in, in respect of material particulars, then it can be held that the goods were being transported with the intention of evasion of tax, even if the goods are supported by bills, vouchers, builty or other supporting material.

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In view of the judgments of apex court supra, the first declaration form bearing no.2167789, which was found at the time of interception of the vehicle, admittedly it was found incomplete as material particulars, namely nature of transaction, invoice/bill/no. on despatch memo, date, value, description of the goods, builty no. etc., in the light of judgment of Guljag Industries (supra) are not filled in.

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Even the subsequent declaration form, though produced by the assessee, in my view can be said to be incomplete, defective or not duly filled in, particularly taking into consideration the additional mandate of law of punching the declaration form, though the learned counsel contended that it is technical error, but in my view it cannot be said to be mere technicality particularly when it is an additional feature introduced by the Government to avoid misuse or reuse of declaration forms and to avoid manipulations by the assessees. To say that it is a technical error, in my view, is not proper. Once the apex court says that declaration form should be complete in all respect, then punching having been introduced as one of the additional feature later, is required to be taken into consideration. What is to be punched is date, month of use and value, which neither the earlier Form nor the new Form was punched and, therefore, in my view the subsequent declaration form can also be said to be incomplete or not duly filled in and is not sufficient compliance of the mandate of law.

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It is surprising that though the Dy. Com. (Appeals) took it as one of the grounds to reject the contention of the assessee in addition to other grounds, however, though the Tax Board did refer to the argument of the Revenue about punching of the declaration form also to be mandatory, but the Tax Board has not at all considered this vital issue which

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ought to have been considered by the Tax Board. It is surprising that the Tax Board has not given any reasoning and ignored this vital issue, which is a perversity.

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In my view, the judgment of Guljag Industries (supra) of which relevant paras have been reproduced hereinbefore, is applicable in the facts and circumstances of the instant case and when the additional feature of punching which has been noticed hereinbefore, the declaration form can be said to be deficient in the light of the judgment rendered in the case of Guljag Industries (supra).

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This court in the case of M/s Agrotech Foods Limited v. ACTO, Flying Squad, Bhadra [STR No.189/2012] decided on 15.9.2016, has already taken a view that punching having been introduced by the Legislature to be done additionally, then it cannot be said to be a technicality and is required to be punched.

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The judgments relied upon by the learned counsel for the assessee are distinguishable in the light of judgments of the apex court in the case of Guljag Industries and D.P. Metals (supra).

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Consequently, in my considered view the declaration form has to be complete in all respect and finding the subsequent form even incomplete in respect

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of material particulars and punching, the order of Tax Board is reversed and that of the AO as well as Dy. Com. (Appeals), are upheld. In the result, the petition succeeds.

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db 55

A C T O Jaipur v. M/S Anil Agencies Pvt. Ltd.

Case brief

What is this about?

What did the court decide?

A C T O Jaipur v. M/S Anil Agencies Pvt. Ltd.

Case brief

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What the court decided

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