M/S. ASHOK LEYLAND LTD.,CHENNAI vs. DCIT, CORPORATE CIRCLE-1(1), CHENNAI

ITA 602/CHNY/2025Status: DisposedITAT Chennai29 July 2025AY 2017-18Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI JAGADISH (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that notices issued for reopening assessment and the reassessment order passed in the name of a non-existent entity, despite the AO being aware of the amalgamation, are void ab initio and null in the eyes of law.

What were the facts?

M/s. Ashok Leyland Vehicles Ltd. (ALVL) amalgamated with M/s. Ashok Leyland Ltd. (ALL) effective from 01.04.2018. Despite being informed of this, the Assessing Officer (AO) issued reassessment notices and the final assessment order in the name of the non-existent entity, ALVL.

What were the issues?

Whether reassessment proceedings initiated and assessment order passed in the name of a non-existent entity after amalgamation are legally valid.

Which sections of the Income-tax Act were involved?

Section 148,Section 143(2),Section 147

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Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & SHRI JAGADISH

Hearing: 25.06.2025Pronounced: 29.07.2025

PER ABY T. VARKEY, JM: This is an appeal preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)/NFAC, (hereinafter

referred to as ‘Ld.CIT(A)‘), Delhi, dated 03.01.2025 for the Assessment

Year (hereinafter referred to as ‘AY‘) 2017-18. 2. The assessee in the grounds taken in the appeal is noted to have objected to the legal validity of the assessment order dated 30.03.2022

and also the merits of the addition(s)/disallowa

The order continues below.

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