Monday, March 2, 2009

TDS on Hire-purchase/Interest Charges




Hi Balu, Jaysukh, Madhu and Rajendra,


Theoretically, you guys are correct. But I am looking at thesubstance of the transaction rather than its form. I understand mostof these car finance companies enter into some sort of an agreementthat on paper at least looks like what may be called a hire-purchaseagreement. But if you look beyond the fine print of the agreement,you'd find these are simple finance transactions with a lender and aborrower. Assessees often try to sidestep their TDS responsibilitiesby advancing the argument that such transactions are Hire-purchasein nature. Since the ownership hasn't passed on to them, whatthey're paying is not interest but hire charges.But in almost all such cases, the same assessees also don't want toforego the depreciation on these assets. They incorporate the costof the car in the books and start claiming depreciation on it rightfrom year one. Now you have to be the owner of the asset in order toclaim depreciation on it. If you've put forward a claim ofdepreciation, you can't in the same breath contend that you'remerely a hire-purchaser, when it comes to making the TDS.So I think if an assessee purported to be a hire-purchaser, isn'tclaiming depreciation on the car, then it might be okay not todeduct TDS on the hire charges paid to Maruti Countrywide, et al.Balu, the CBDT circular of 1981 you've quoted from must have had itsrelevance in its heyday, but not any more. There's a huge emphasison Substance over Form in interpreting business transactions thesedays. And yes we have to refer to AS 19 as well to resolve thisissue, in view of the fact that AS 19 includes hire-purchaseagreements within the meaning of leases. There're two kinds ofleases: A Finance lease and an Operating lease. Hire-purchasecontracts are treated as finance leases. The soul of a finance leaseis the passing of all risks and rewards of ownership of the asset tothe lessee. Since this practically makes the lessee the owner of theasset, AS 19 requires us to recognize the leased asset in the booksof the lessee. Not doing so wouldn't reflect a true and fair view ofthe state of affairs. An asset actively deployed in the services ofthe business ought to be reflected in the books at some value.The Supreme court in the case of Asea Brown Boveri Ltd. v.Industrial Finance Corpn. of India [2005] 56 SCL 21 hascategorically said that a finance lease is merely a loan indisguise. A finance lease is a transaction current in the commercialworld, its primary purpose being the financing of the asset by thepurchaser, the court said.Another thing to be noted is lessor in finance lease cases istypically a financial institution, like we have the MarutiContrywide in the instant case. By its very nature, a financialinstitution is in the business of dispensing money. It merelystepped in as an intermediary between the assessee and the cardealer. Maruti Countrywide and other such finance companies havebeen formed for engaging in the business of financing and not thebusiness of giving assets on hire. Section 194-I, in my opinion,gets attracted where the person we hire the equipment from is in thebusiness of giving those equipments on hire. A car finance companyisn't in the business of giving cars on hire. The car has alreadybeen bought and sold for. The dealer is out of the picture. MarutiCountrywide made the payment on our behalf on the promise that weshall repay it over a period of time. We can't say we hired the carfrom Maruti Countrywide.So methinks, TDS u/s 194A would be applicable on the interest(doesn't matter what you call that amount—Substance over Form!)comprised in the EMIs paid to the car finance company.And Mr Soodan, yes that's a practical problem—how to "deduct" TDSwhen you've already parted with the pre-filled PDCs? I guess wemight have to somehow recover the tax amount from them separatelyagainst the issue of Form 16-A. The TDS issues need to be clearlysorted out before we go in for financing through these privatecompanies.Thanks,CA Sanjeev Bedi--- In
ICAI_CIRC_MEERUT_CA@yahoogroups.com, "balunand" wrote:>>> The instant case is one of Hire Purchase and since the vehiclecan be> repossessed anytime during the period of contract for default, the> additional amount paid is only hire charges and not interest. This> view has been given by the CBDT itself in the context of InterestTax> Act in Instruction No. 1425 in F. No. 275/9/80-IT(B) dated> 16-11-1.981, which is reproduced below.>> 'In a hire-purchase contract the owner delivers goods to another> person upon terms on which the hirer is to hire them on a fixed> periodical rental. The hirer has also the option of purchasing the> goods by paying the total amount of agreed hire at any time or of> returning the same before the total amount is paid. It may bepointed> out that part of the amount of the hire-purchase price is towardsthe> hire and part towards the payment of price. The agreed amountpayable> by the hirer in periodical instalments cannot, therefore, be> characterised as interest payable in any manner with the meaning of> section 2(28A) of the Income-tax Act, as it is not in respect ofany> money borrowed or debt incurred. In this view of the matter, it is> clarified that the provisions of section 194A of the Income-tax Act> are not attracted in these transactions.'>> Now the question is would sec 194I be attracted?>> Balu> > From: ICAI_CIRC_MEERUT_CA@yahoogroups.com> > [mailto:ICAI_CIRC_MEERUT_CA@yahoogroups.com] On Behalf OfSanjeev Bedi> > Sent: 22 December 2008 22:08> > To: ICAI_CIRC_MEERUT_CA@yahoogroups.com> > Subject: {amresh's-CA's} Re: TDS on Interest on car loan fromMaruti> > Countrywide> >> >> >> > Hi Mr Mohan, Madhu and Gowdhaman,> >> > In my opinion, TDS would be deductible u/s 194A. This is because> > Maruti Countrywide is neither a banking company registered underthe> > BRA 1949 nor a body that's been notified by the government u/s194A> > (3)(iii)(f). And companies like Maruti Countrywide and Kotak> > Mahindra don't seem to be covered under any of the otherexemptions> > listed in sub-section 3 of Section 194A either.> >> > The onus to prove that TDS isn't deductible on interest toMaruti> > Countrywide or the like is on those who claim so. If we can'tfind a> > notification or circular supporting such a claim, Section 194A> > stands applicable to such interest payments.> >> > Thanks,> >> > CA Sanjeev Bedi> >> > --- In ICAI_CIRC_MEERUT_CA@yahoogroups.com> > , madhu tapuriah> > wrote:> > >> > > but why? under which provisions ????> > >> > > --- On Mon, 22/12/08, gowdham wrote:> > > From: gowdham > > > Subject: Re: {amresh's-CA's} TDS ON INTEREST ON LOAN> > > To: ICAI_CIRC_MEERUT_CA@yahoogroups.com> > > > > Date: Monday, 22 December, 2008, 10:56 AM> > >> > >> > >> > >> > >> > >> > >> > >> > >> > >> > >> > > Dear Mr.Mohan,> > > Â> > > You need not deduct TDS.> > > Â> > > Thanks &regards> > >> > >> > > R.S.GOWDHAMAN> > >> > > --- On Fri, 19/12/08, mohangee wrote:> > >> > > From: mohangee > > > Subject: {amresh's-CA' s} TDS ON INTEREST ON LOAN> > > To: ICAI_CIRC_MEERUT_ CA@yahoogroups. com> > > Date: Friday, 19 December, 2008, 12:33 PM> > >> > >> > >> > >> > >> > > Sir,> > > My client is a partnership firm took loan from maruthi country> > wide for a vehicle.> > > Whether tds is to be deducted for the interest paid on loanto> > maruthi countrywide?> > > CA MohanÂ

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