PCIT v. Mahagun Realtors Pvt. Ltd.

443 ITR 194Supreme Court of India2022#1196 most cited

What is PCIT v. Mahagun Realtors Pvt. Ltd. authority for?

An assessment framed by the Assessing Officer in the name of a defunct transferor company is valid if the assessee failed to intimate the AO about the merger or amalgamation.

95

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2022 to 2026.

Also referred to as

PCIT v. Mahagun Realtors Pvt. Ltd. · 443 ITR 194 · 19 SCC 1 · assessment validity · amalgamation · merger · transferor company · defunct company · intimation to AO · section 143(3) · section 147 · section 292B

Also reported as

19 SCC 1

Sections most often in play

Section 143(3)Section 148Section 292BSection 147Section 143(2)Section 142(1)Section 153ASection 250

Issues it is cited on

section 2(1a)transferor companytransferee companysection 39section 14(a)section 2(31)amalgamationsection 292bsection 153a(1)(b)construction pesection 292section 24(a)

Judgments citing PCIT v. Mahagun Realtors Pvt. Ltd.

PRINCIPAL COMMISSIONER OF INCOME TAX-1 vs. BOEING INDIA PVT. LTD.

The appeal is dismissed

ITA/586/2025HC Delhi16 Mar 2026

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

For Appellant: Mr. Debesh Panda, SSC, Ms. Zehra KhanFor Respondent: Mr. Sachit Jolly, Sr Advocate with Ms
Section 143(2)Section 144CSection 260A

…f. Whether the Hon‟ble ITAT has erred in not considering the fact that the case of the assessee company is covered by the pronouncement of Hon‟ble Supreme Court in the case of Principal Commissioner of Income Tax (Central)-2 v. Mahagun Realtors (P) Ltd. 2022 SCC OnLine SC 407? g. Whether on facts and circumstances of the case and law, the order of the ITAT is perverse in nature?” ANALYSIS 21. Having heard the learned counsel for the parties and perused the record, the short issue that arises for consideration before this Court is whether the final assessment order dated 30.03.2021 issued in the name…

PRINCIPAL COMMISSIONER OF INCOME TAX-1 vs. BOEING INDIA PVT. LTD.

The appeal is dismissed

ITA-586/2025HC Delhi16 Mar 2026
For Appellant: Mr. Debesh Panda, SSC, Ms. Zehra KhanFor Respondent: Mr. Sachit Jolly, Sr Advocate with Ms
Section 143(2)Section 144CSection 260A

…f. Whether the Hon‟ble ITAT has erred in not considering the fact that the case of the assessee company is covered by the pronouncement of Hon‟ble Supreme Court in the case of Principal Commissioner of Income Tax (Central)-2 v. Mahagun Realtors (P) Ltd. 2022 SCC OnLine SC 407? g. Whether on facts and circumstances of the case and law, the order of the ITAT is perverse in nature?” ANALYSIS 21. Having heard the learned counsel for the parties and perused the record, the short issue that arises for consideration before this Court is whether the final assessment order dated 30.03.2021 issued in the name…

ERSTWHILE BIHAR KSHETRIYA GRAMIN BANK ,PATNA vs. ASST COMMISSIONER OF INCOME-TAX, CIRCLE 1, PATNA

In the result, the appeal filed by the Assessee is partly allowed for statistical purposes

ITA 459/PAT/2025[2017-2018]Status: DisposedITAT Patna19 Feb 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 133(6)Section 147Section 250Section 481

…IN THE INCOME TAX APPELLATE TRIBUNAL PATNA ‘DB’ BENCH AT KOLKATA [Virtual Court] Before SHRI SONJOY SARMA, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT MEMBER ITA No(s).: 459/PAT/2025 Assessment Year(s): 2017-18 Erstwhile Bihar Kshetriya ACIT, Circle-1, Patna Gramin Bank Vs. (Appellant) (Respondent) PAN: AACCB7804J Appearances: Assessee represented by : Nishant Maitin, CA. Department represented by : Md. A H Chowdhury, CIT (DR). Date of concluding the hearing : 06-January-2026 Date of pronouncing the order : 19-February-2026 ORDER PER RAKESH MISHRA, ACCOUNTANT MEMBER: This appeal filed by the Assessee is agai…

ACIT-2(1)(1), MUMBAI vs. BANK OF BARODA (E- VIJAYA BANK), MUMBAI

In the result, the appeal filed by the assessee is allowed and the appeal filed by the

ITA 2942/MUM/2024[2019-20]Status: DisposedITAT Mumbai10 Feb 2026AY 2019-20

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Vimal Kumar Meena, (CIT DR)
Section 143(2)Section 143(3)Section 250Section 292Section 41

…rejudice to the assessee was caused due to the action of the Ld. AO in passing the assessment order in the name of the amalgamating company. The Ld. DR also drew support from decision to the Hon’ble Apex Court in the case of Mahagun Relators (P) Ltd. (2022) 443 ITR 194 (SC) where identical issue was decided in favour of the Revenue. ITA No.2942/Mum/2024 & Ors. Bank of Baroda (e-Vijaya Bank) 9. We have heard the rival submissions and perused the materials available on record. 10. The impugned issue that requires adjudication is whether the assessment order passed in the name of non-existent entity would rende…

BANK OF BARODA (ERSTWHILE VIJAYA BANK),MUMBAI vs. ASSESSING OFFICER, NFAC, NEW DELHI, NFAC, NEW DELHI

In the result, the appeal filed by the assessee is allowed and the appeal filed by the

ITA 2533/MUM/2024[2019-20]Status: DisposedITAT Mumbai10 Feb 2026AY 2019-20

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Vimal Kumar Meena, (CIT DR)
Section 143(2)Section 143(3)Section 250Section 292Section 41

…rejudice to the assessee was caused due to the action of the Ld. AO in passing the assessment order in the name of the amalgamating company. The Ld. DR also drew support from decision to the Hon’ble Apex Court in the case of Mahagun Relators (P) Ltd. (2022) 443 ITR 194 (SC) where identical issue was decided in favour of the Revenue. ITA No.2942/Mum/2024 & Ors. Bank of Baroda (e-Vijaya Bank) 9. We have heard the rival submissions and perused the materials available on record. 10. The impugned issue that requires adjudication is whether the assessment order passed in the name of non-existent entity would rende…

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN ,MUMBAI vs. ITO WARD-1 PALGHAR , MUMBAI

In the result, all four appeals of the assessee stand allowed

ITA 7677/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

Section 142(1)Section 144Section 147Section 148Section 151Section 159Section 271FSection 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER 1. ITA No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. ITA No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. ITA No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. ITA No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain as Legal ITO Ward-1, heir of Bhawarlal Shrilal BIDCO Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. PAN/GIR No. ABJPJ5270F (Applicant) (Respondent) Assessee by Sh…

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN ,MUMBAI vs. ITO WARD -1 PALGHAR , THANE

In the result, all four appeals of the assessee stand allowed

ITA 7676/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

Section 142(1)Section 144Section 147Section 148Section 151Section 159Section 271FSection 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER 1. ITA No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. ITA No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. ITA No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. ITA No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain as Legal ITO Ward-1, heir of Bhawarlal Shrilal BIDCO Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. PAN/GIR No. ABJPJ5270F (Applicant) (Respondent) Assessee by Sh…

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN,MUMBAI vs. ITO WARD 1 PALGHAR, THANE

In the result, all four appeals of the assessee stand allowed

ITA 7675/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

Section 142(1)Section 144Section 147Section 148Section 151Section 159Section 271FSection 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER 1. ITA No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. ITA No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. ITA No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. ITA No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain as Legal ITO Ward-1, heir of Bhawarlal Shrilal BIDCO Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. PAN/GIR No. ABJPJ5270F (Applicant) (Respondent) Assessee by Sh…

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN ,MUMBAI vs. ITO WARD 1, PALGHAR , THANE

In the result, all four appeals of the assessee stand allowed

ITA 7674/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

Section 142(1)Section 144Section 147Section 148Section 151Section 159Section 271FSection 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER 1. ITA No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. ITA No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. ITA No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. ITA No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain as Legal ITO Ward-1, heir of Bhawarlal Shrilal BIDCO Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. PAN/GIR No. ABJPJ5270F (Applicant) (Respondent) Assessee by Sh…

SAROJ GUPTA,DELHI vs. DCIT,CENTRAL CIRCLE-25, DELHI

In the result, assessee’s appeals are allowed

ITA 3944/DEL/2025[2020-21]Status: DisposedITAT Delhi28 Jan 2026AY 2020-21

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

Section 153C

…1 ITA Nos. 3938-3944/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”: NEW DELHI BEFORE Ms. MADHUMITA ROY, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA Nos. 3938, 3939, 3940, 3941, 3942, 3943 & 3944/DEL/2025 A. Yrs: 2014-15, 2015-16, 2016-17, 2017-18, 2018-19, 2019-20 & 2020-21 Saroj Gupta (legal representative of Shri Vs DCIT, Central Circle-25, Pawan Kumar Gupta) New Delhi. C-115, Mahandru Enclave, Delhi-110033. PAN: AAHPG 7894 D APPELLANT RESPONDENT Assessee represented by Shri Salil Kapoor, Adv. Shri Sumit Lalchandani, Adv. Shri Shivam Yadav, Ad. Department represented by Shr…

SAROJ GUPTA,DELHI vs. DCIT,CENTRAL CIRCLE-25, DELHI

In the result, assessee’s appeals are allowed

ITA 3943/DEL/2025[2019-20]Status: DisposedITAT Delhi28 Jan 2026AY 2019-20

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

Section 153C

…1 ITA Nos. 3938-3944/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”: NEW DELHI BEFORE Ms. MADHUMITA ROY, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA Nos. 3938, 3939, 3940, 3941, 3942, 3943 & 3944/DEL/2025 A. Yrs: 2014-15, 2015-16, 2016-17, 2017-18, 2018-19, 2019-20 & 2020-21 Saroj Gupta (legal representative of Shri Vs DCIT, Central Circle-25, Pawan Kumar Gupta) New Delhi. C-115, Mahandru Enclave, Delhi-110033. PAN: AAHPG 7894 D APPELLANT RESPONDENT Assessee represented by Shri Salil Kapoor, Adv. Shri Sumit Lalchandani, Adv. Shri Shivam Yadav, Ad. Department represented by Shr…

SAROJ GUPTA,DELHI vs. DCIT,CENTRAL CIRCLE-25, DELHI

In the result, assessee’s appeals are allowed

ITA 3942/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Jan 2026AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

Section 153C

…1 ITA Nos. 3938-3944/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”: NEW DELHI BEFORE Ms. MADHUMITA ROY, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA Nos. 3938, 3939, 3940, 3941, 3942, 3943 & 3944/DEL/2025 A. Yrs: 2014-15, 2015-16, 2016-17, 2017-18, 2018-19, 2019-20 & 2020-21 Saroj Gupta (legal representative of Shri Vs DCIT, Central Circle-25, Pawan Kumar Gupta) New Delhi. C-115, Mahandru Enclave, Delhi-110033. PAN: AAHPG 7894 D APPELLANT RESPONDENT Assessee represented by Shri Salil Kapoor, Adv. Shri Sumit Lalchandani, Adv. Shri Shivam Yadav, Ad. Department represented by Shr…

SAROJ GUPTA,DELHI vs. DCIT,CENTRAL CIRCLE-25, DELHI

In the result, assessee’s appeals are allowed

ITA 3941/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Jan 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

Section 153C

…1 ITA Nos. 3938-3944/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”: NEW DELHI BEFORE Ms. MADHUMITA ROY, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA Nos. 3938, 3939, 3940, 3941, 3942, 3943 & 3944/DEL/2025 A. Yrs: 2014-15, 2015-16, 2016-17, 2017-18, 2018-19, 2019-20 & 2020-21 Saroj Gupta (legal representative of Shri Vs DCIT, Central Circle-25, Pawan Kumar Gupta) New Delhi. C-115, Mahandru Enclave, Delhi-110033. PAN: AAHPG 7894 D APPELLANT RESPONDENT Assessee represented by Shri Salil Kapoor, Adv. Shri Sumit Lalchandani, Adv. Shri Shivam Yadav, Ad. Department represented by Shr…

SAROJ GUPTA,DELHI vs. DCIT,CENTRAL CIRCLE-25, DELHI

In the result, assessee’s appeals are allowed

ITA 3940/DEL/2025[2016-17]Status: DisposedITAT Delhi28 Jan 2026AY 2016-17

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

Section 153C

…1 ITA Nos. 3938-3944/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”: NEW DELHI BEFORE Ms. MADHUMITA ROY, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA Nos. 3938, 3939, 3940, 3941, 3942, 3943 & 3944/DEL/2025 A. Yrs: 2014-15, 2015-16, 2016-17, 2017-18, 2018-19, 2019-20 & 2020-21 Saroj Gupta (legal representative of Shri Vs DCIT, Central Circle-25, Pawan Kumar Gupta) New Delhi. C-115, Mahandru Enclave, Delhi-110033. PAN: AAHPG 7894 D APPELLANT RESPONDENT Assessee represented by Shri Salil Kapoor, Adv. Shri Sumit Lalchandani, Adv. Shri Shivam Yadav, Ad. Department represented by Shr…

SAROJ GUPTA,DELHI vs. DCIT,CENTRAL CIRCLE-25, DELHI

In the result, assessee’s appeals are allowed

ITA 3939/DEL/2025[2015-16]Status: DisposedITAT Delhi28 Jan 2026AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

Section 153C

…1 ITA Nos. 3938-3944/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”: NEW DELHI BEFORE Ms. MADHUMITA ROY, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA Nos. 3938, 3939, 3940, 3941, 3942, 3943 & 3944/DEL/2025 A. Yrs: 2014-15, 2015-16, 2016-17, 2017-18, 2018-19, 2019-20 & 2020-21 Saroj Gupta (legal representative of Shri Vs DCIT, Central Circle-25, Pawan Kumar Gupta) New Delhi. C-115, Mahandru Enclave, Delhi-110033. PAN: AAHPG 7894 D APPELLANT RESPONDENT Assessee represented by Shri Salil Kapoor, Adv. Shri Sumit Lalchandani, Adv. Shri Shivam Yadav, Ad. Department represented by Shr…

SAROJ GUPTA,DELHI vs. DCIT,CENTRAL CIRCLE-25, DELHI

In the result, assessee’s appeals are allowed

ITA 3938/DEL/2025[2014-15]Status: DisposedITAT Delhi28 Jan 2026AY 2014-15

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

Section 153C

…1 ITA Nos. 3938-3944/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”: NEW DELHI BEFORE Ms. MADHUMITA ROY, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA Nos. 3938, 3939, 3940, 3941, 3942, 3943 & 3944/DEL/2025 A. Yrs: 2014-15, 2015-16, 2016-17, 2017-18, 2018-19, 2019-20 & 2020-21 Saroj Gupta (legal representative of Shri Vs DCIT, Central Circle-25, Pawan Kumar Gupta) New Delhi. C-115, Mahandru Enclave, Delhi-110033. PAN: AAHPG 7894 D APPELLANT RESPONDENT Assessee represented by Shri Salil Kapoor, Adv. Shri Sumit Lalchandani, Adv. Shri Shivam Yadav, Ad. Department represented by Shr…

M/S JINDAL EQUIPMENT LEASING CONSULTANCY SERVICES LTD. vs. COMMISSIONER OF INCOME TAX

Appeals stand disposed of in the aforesaid terms

C.A. No.-000152-000152 - 2026Supreme Court09 Jan 2026

Bench: HON'BLE MR. JUSTICE R. MAHADEVAN

Section 143(3)Section 28Section 47

…o exist. Yet, in every other sense of the term, the corporate venture continues — enfolded within the new or the existing transferee entity. In other words, the business and the adventure lives on but within a new corporate 27 (2024) 1 SCC 797 28 (2022) 19 SCC 1 33 residence i.e. the transferee company. It is, therefore, essential to look beyond the mere concept of destruction of corporate entity which brings to an end or terminates any assessment proceedings. There are analogies in civil law and procedure where upon amalgamation, the cause of action or the complaint does not per se cease — depend…

UNIQUE RAIL ROAD CONSULTANTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(3), HYDERABAD

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1277/HYD/2025[2015-16]Status: DisposedITAT Hyderabad19 Dec 2025AY 2015-16

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 143(3)Section 250Section 44A

…e assessee on the issue of passing of assessment order in the name of non-existing entity, the Ld. CIT(A) by taking note of relevant facts and also by following the decision of Hon'ble Supreme Court in the case of Pr. CIT Vs. Mahagun Realtors Pvt. Ltd. [2022] 443 ITR 194 (SC) held that the assessee has failed to provide relevant details of 7 Unique Rail Road Consultants Pvt. Ltd. amalgamation of the assessee company with M/s. United Rail Road Consultants Pvt. Ltd. before the A.O. when he has passed the assessment order. Since the assessee has not filed relevant details of amalgamation and informed the A.O. about…

JCIT(OSD), DELHI vs. M/S IGT SOLUTION PRIVATE LIMITED, MAHARASTRA

The appeal of the Revenue is dismissed

ITA 2126/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year : 2017-18 Jcit (Osd), Vs. M/S Igt Solution Private Ltd., Circle-10(1), Unit No.1, Ground Floor, New Delhi. A Wing, Business2Mantri, Survey No.197/2 To 4 To 7B, Dukirklines, So Pune City, Pune – 411014, Maharashtra. Pan: Aaaci5079A (Appellant) (Respondent) Assessee By : Ms Priya Tandon, Advocate Revenue By : Shri Mahesh Kumar, Cit-Dr Date Of Hearing : 15.09.2025 Date Of Pronouncement : 30.10.2025 Order

For Appellant: Ms Priya Tandon, AdvocateFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 143(3)

…t the ld.CIT has followed the decision of the Hon’ble Supreme Court in the case of PCIT v. Maruti Suzuki India Ltd [2019]107 taxmann.com 375 (SC) and there 2 has been failure to consider the subsequent decision in PCIT (Central) v. Mahagun Realtors (P) Ltd. [2022 SCC OnLine SC 407. However, as we go through the facts and circumstances, we find that the assessee had duly informed the fact the erstwhile company had seized to exist, yet, the reassessment notice was issued in the name of the erstwhile company. Reliance in this regard is rightly placed on the decision of the Hon’ble Delhi High Court in the case of Sk…

DCIT CIRCLE 2.3.1, MUMBAI, MUMBAI vs. PRESTIGE HOLIDAY RESORTS PRIVATE LIMITED, MUMBAI

In the result, ground no. 2 and 3 are

ITA 4162/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Oct 2025AY 2016-17

Bench: Shri Pawan Singh& Shri Arun Khodpia

Section 2(11)Section 2(22)(e)Section 253(3)Section 254(1)

…on, the ld. Sr DR of the revenue relied on the decision of Hon’ble Delhi High Court in Sky Light Hospitality LLP vs ACIT which has been approved by Hon’ble Apex Court in Sky Light Hospitality vs ACIT 405 ITR(St) 12 (SC) and PCIT vs Mahagun Realtors (P) Ltd. 443 ITR 194 (SC). The ld. CIT-DR for the revenue submits that in PCIT vs Mahagun Realtors (P) Ltd. held that assessment order passed in amalgamated company was valid. 46. In rejoinder submission, the ld. AR of the assessee submits that case law relied by ld. DR in Sky Light Hospitality (supra) is devoid of merit, for the reasons that said decision consid…

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