BOKARO INDUSTRIAL AREA DEVELOPMENT AUTHORITY,BOKARO vs. DCIT, CIRCLE-3(1), BOKARO, BOKARO
What did the Tribunal hold?
The Tribunal held that the notice under Section 148 was validly issued as BIADA's PAN was active and the department had not been formally intimated of the merger. However, subsequent assessment proceedings should have continued in the name of JIADA.
What were the facts?
The assessee, Bokaro Industrial Area Development Authority (BIADA), was merged with Jharkhand Industrial Area Development Authority (JIADA) in 2016. The assessee argued that notices under Section 148 were issued to a non-existent entity, rendering the assessment invalid. The revenue contended that BIADA's PAN was still active when the notice was issued.
What were the issues?
Whether assessment proceedings initiated under Section 148 are valid when the assessee entity has merged with another entity. Whether subsequent assessment proceedings should be continued in the name of the merged entity.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI
Before: S/SHRI GEORGE MATHAN & RATNESH NANDAN SAHAY
Per Bench These are appeals filed by the assessee against the separate orders of the ld CIT(A), NFAC, Delhi all dated 10.01.2024 in Appeal No. CIT(A) Hazaribagh/10113/2019-20, CIT(A) Hazaribagh/10114/2019-20, CIT(A) Hazaribagh/10115/2019-20, CIT(A) Hazaribagh/10116/2019-20 and CIT(A) Hazaribagh/10117/2019-20 for the assessment years 2012-13 to 2016-17 respectively.
Shri Vinay Kumar Jalan, ld AR appeared for the assessee and Shri Ashish Kumar Deharia, ld CIT DR appeared for the revenue. P a g e 1 | 5
ITA No. 108 to 112 /RAN/2024 Assessment Years 2012-13 to 2016-17
It was submitted by AR that assessee (Bokaro Industrial Are
The order continues below.
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- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
- Adj Agri International LLP, Rajkot vs The Income Tax Officer, Ward-1(1)(1), RajkotITA 1198/RJT/2026[2018-19]Status: Disposed21 Oct 2026AY 2018-19
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