Facts of the Case
The appellant, T & T Motors Ltd., is an automobile dealer.
During the assessment year 2006-07, the company provided various car
accessories to customers "free of cost" (FOC) at the time of car
booking and sale. The Assessing Officer (AO) classified these FOC accessories
as "hospitality" under Section 115WB(2)(B) of the Income Tax Act,
1961, or alternatively as "sales promotion" expenses under Section
115WB(2)(D), and consequently levied Fringe Benefit Tax (FBT) on 20% of the
expenditure incurred. Both the CIT (Appeals) and the Income Tax Appellate
Tribunal (ITAT) upheld the AO's view, considering the provision of accessories
as a promotional scheme.
Issues Involved
The Court addressed two substantial questions of law:
- Whether
the Tribunal was correct in holding that FOC accessories provided to
customers at the time of car sales were in the nature of "sales
promotion expenses" and not "selling expenses".
- Whether
such FOC accessories are covered under Section 115WA read with Clause (D)
of Section 115WB(2) of the Income Tax Act, 1961.
Petitioner’s Arguments
The appellant argued that the provision of accessories does
not constitute "hospitality" as defined by law. Furthermore, they
contended that providing these accessories was not a "sales
promotion" or "publicity" activity, but rather a form of sales
discount or rebate—similar to reducing the sale price—to secure a favorable
deal for the customer. They relied on CBDT Circular No. 8 of 2005 (Question
60), which clarifies that discounts or rebates to customers are "selling
expenses" and fall outside the scope of FBT.
Respondent’s Arguments
The Revenue contended that the FOC accessories were provided
to boost sales, categorizing the expenditure as "sales promotion"
under Section 115WB(2)(D). The Revenue argued that these expenses were not
"selling expenses" and relied on CBDT Circular No. 8 of 2005
(Question 66), which suggests that "free offers" (freebies) provided
to consumers are liable for FBT.
Court Order/Findings
The Delhi High Court ruled in favor of the appellant, holding
that:
- Not
Hospitality: Providing car accessories to a purchaser
cannot be equated to "hospitality," which implies the reception
and entertainment of guests.
- Selling
Expense vs. Sales Promotion: The accessories were not
independent gifts but were part of the sale transaction. The customer
essentially pays for the accessories as part of the total sale
consideration. Therefore, this practice is akin to a "discount"
or "rebate" provided to a customer, which falls under
"selling expenses" and not "sales promotion".
- CBDT
Circular Interpretation: The Court distinguished the
present case from the "freebies" (like tattoos or cards)
mentioned in Question 66 of the CBDT Circular, noting that car accessories
are integral to the utility and enjoyment of the vehicle purchased.
Important Clarification
The Court clarified that the expression "sales
promotion" should not be confused with the actual sale of goods. When an
assessee provides a better deal to a customer through inclusive fitments as
part of a bargain for the sale consideration, it is a commercial practice of
discounting, not a fringe benefit provided to an employee or a promotional
expense subject to FBT.
Section Involved
- Section
115WA: Charging section for Fringe Benefit Tax.
- Section
115WB(2)(B): Defines fringe benefits relating to
"hospitality".
- Section 115WB(2)(D): Defines fringe benefits relating to "sales promotion including publicity".
Link to download the order -https://delhihighcourt.nic.in/app/case_number_pdf/2012:DHC:495-DB/SKN24012012ITA8992010.pdf
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