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.

How many judgments cite PCIT v. Mahagun Realtors Pvt. Ltd.?

95 judgments on BharatTax cite PCIT v. Mahagun Realtors Pvt. Ltd. (443 ITR 194), spanning 2022 to 2026.

Which sections of the Income Tax Act does PCIT v. Mahagun Realtors Pvt. Ltd. come up under?

It is most often cited in judgments turning on Section 143(3), Section 148, Section 292B, Section 147, Section 143(2), Section 142(1).

PCIT v. Mahagun Realtors Pvt. Ltd. (443 ITR 194)

DCIT Circle 2.3.1, Mumbai vs. Prestige Holiday Resorts Private Limited, Mumbai

In the result, ground no. 2 and 3 are

ITA 4161/MUM/2025[2015-16]Status: DisposedITAT Mumbai28 Oct 2025AY 2015-16

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…

Deputy Commissioner of Income-Tax, Central Circle-2(2), Bengaluru vs. M/S Trishul Developers, Bengaluru

ITA 767/BANG/2025[2010-11]Status: DisposedITAT Bangalore29 Sept 2025AY 2010-11

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. Muthu Shankar, CIT(DR)(ITAT), Bangalore

Section 132Section 153ASection 153CSection 292Section 69C

…, and since such notice had not been issued to transferee- company, entire proceedings were a nullity." 7.18 We are also very conscious about the latest decision of Hon'ble Supreme Court in the case of Principal CIT Vs. Mahaguna Realtors Pvt. Ltd. reported in 443 ITR 194 (SC), wherein held as follows: "Amalgamation was known to assessee, even at the stage when the search and seizure operations took place, as well as statements were recorded by the revenue of the directors and managing director of the group. A return was filed, pursuant to notice, which suppressed the fact of amalgamation; on the contrary, the ret…

DCIT, New Delhi vs. M/S Khaitan Holdings (Mauritius) Ltd., Mauritius

In the result, the appeal is dismissed

ITA 3275/DEL/2015[2006-07]Status: DisposedITAT Mumbai25 Aug 2025AY 2006-07

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am Dy. Cit, Circle-2(1)(2) (Intl. Tax.) M/S. Khaitan Holdings (Mauritius) New Delhi Ltd. (Erstwhile Black Lion Ltd.) C/O. Axis Fiduciary Ltd. Vs. 2Nd Floor, The Axis, 26 Cybercity Ebene 722 201, Mauritius

For Respondent: Shri Krishna Kumar (Sr. DR)

Section 142(1)Section 144C(3)Section 147Section 148

…ot only followed the ratio laid down by the Hon'ble Supreme Court in the case of Pr. CIT vs. Maruti Suzuki India Ltd. (supra), but has also distinguished the decision of the Hon'ble Supreme Court in the case of Pr. CIT vs. Mahagun Realtors (P.) Ltd. [2022] 443 ITR 194 (SC) due to its specific facts. Suffice to say, in case of Mahagun Realtors (P.) Ltd. (supra), there is concurrent finding of fact that the assessee never intimated the fact of merger/amalgamation to the A.O. Whereas, in the facts of the present appeal, not only the assessee on multiple occasions intimated the A.O. about the merger/amalgamation…

Btl Industries Ltd, New Delhi vs. DCIT, Central Circle-II, Faridabad

In the result, appeals of the assessee are partly allowed

ITA 7430/DEL/2019[2008-09]Status: DisposedITAT Delhi20 Aug 2025AY 2008-09

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahman

Section 143(2)Section 14ASection 153Section 153ASection 153A(1)(b)Section 234B

…d the AO about the merger of assessee company with BTL Investment & Security Ltd. and therefore the assessments were validly framed by the AO. Reliance was placed on the decision of the Hon'ble Supreme Court in the case of PCIT vs. Mahagun Realtors Pvt. Ltd. [443 ITR 194]. 7. In the rejoinder Ld. Counsel for the assessee submitted that the decision of the Hon'ble Supreme Court in the case of PCIT vs. Mahagun Realtors Pvt. Ltd. (supra) has no application to the facts of the assessee's case since the assessee vide letters dated 01.09.2014 which is placed at page 47, letter 10 ITA Nos.7430/Del/2019 & 3618 to 3620…

Btl Industries Ltd, New Delhi vs. DCIT, Central Circle-II, Faridabad

ITA 3620/DEL/2018[2013-14]Status: DisposedITAT Delhi20 Aug 2025AY 2013-14

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahman

Section 143(2)Section 14ASection 153Section 153ASection 153A(1)(b)Section 234B

…d the AO about the merger of assessee company with BTL Investment & Security Ltd. and therefore the assessments were validly framed by the AO. Reliance was placed on the decision of the Hon'ble Supreme Court in the case of PCIT vs. Mahagun Realtors Pvt. Ltd. [443 ITR 194]. 7. In the rejoinder Ld. Counsel for the assessee submitted that the decision of the Hon'ble Supreme Court in the case of PCIT vs. Mahagun Realtors Pvt. Ltd. (supra) has no application to the facts of the assessee's case since the assessee vide letters dated 01.09.2014 which is placed at page 47, letter 10 ITA Nos.7430/Del/2019 & 3618 to 3620…

Btl Industries Ltd, New Delhi vs. DCIT, Central Circle-II, Faridabad

In the result, appeals of the assessee are partly allowed

ITA 3619/DEL/2018[2011-12]Status: DisposedITAT Delhi20 Aug 2025AY 2011-12

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahmanassessment Year: 2008-09 बनाम Btl Industries Ltd., Dcit, (Merged With & Now Known As Vs. Central Circle-Ii, M/S Btl Holding Co. Ltd.), Faridabad, C/O Srs Mall, Third Floor, Haryana. Sector-12, Faridabad, Haryana. Pan No.Aaccb0573C अपीलाथ" Appellant ""यथ"/Respondent &

Section 143(2)Section 14ASection 153Section 153ASection 153A(1)(b)Section 234B

…the AO about the merger of assessee company with BTL Investment & Security Ltd. and therefore the assessments were validly framed by the AO. Reliance was placed on the decision of the Hon’ble Supreme Court in the case of PCIT vs. Mahagun Realtors Pvt. Ltd. [443 ITR 194]. 7. In the rejoinder Ld. Counsel for the assessee submitted that the decision of the Hon’ble Supreme Court in the case of PCIT vs. Mahagun Realtors Pvt. Ltd. (supra) has no application to the facts of the assessee’s case since the assessee vide letters dated 01.09.2014 which is placed at page 47, letter dated 15.11.2014 which is placed at pa…

Btl Industries Ltd, New Delhi vs. DCIT, Central Circle-II, Faridabad

ITA 3618/DEL/2018[2010-11]Status: DisposedITAT Delhi20 Aug 2025AY 2010-11

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahman

Section 143(2)Section 14ASection 153Section 153ASection 153A(1)(b)Section 234B

…d the AO about the merger of assessee company with BTL Investment & Security Ltd. and therefore the assessments were validly framed by the AO. Reliance was placed on the decision of the Hon'ble Supreme Court in the case of PCIT vs. Mahagun Realtors Pvt. Ltd. [443 ITR 194]. 7. In the rejoinder Ld. Counsel for the assessee submitted that the decision of the Hon'ble Supreme Court in the case of PCIT vs. Mahagun Realtors Pvt. Ltd. (supra) has no application to the facts of the assessee's case since the assessee vide letters dated 01.09.2014 which is placed at page 47, letter 10 dated 15.11.2014 which is placed at p…

Ishwar Chand Aggarwal, Faridabad vs. Income Tax Officer- Ward 1(3), New Cgo Complex

ITA 2844/DEL/2024[2014-15]Status: DisposedITAT Delhi31 Jul 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Avdhesh Kumar Mishraishwar Chand Aggarwal Vs. Ito, Ward 1(3) 3D-29, Nit Faridabad Nh-4, Nit, Haryana – 121001 Faridabad, Haryana "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aalpa5364Q Appellant .. Respondent

For Appellant: Sh. Jitender Wadhwa, CAFor Respondent: Sh. Om Prakash, Sr. DR

Section 142(1)Section 144Section 147Section 148

…ders the assumption of jurisdiction invalid as was the ultimate finding of the Ld. CIT(A) particularly relying upon the judgement passed by the Hon'ble Supreme Court in the case of Pr. CIT v. Mahagun Realtors (P.) Ltd. [2022] 137 taxmann.com 91/287 Taxman 566/443 ITR 194 (SC). He therefore, held the assumption of jurisdiction to be invalid and allowed the appeal preferred by the assessee with the following observations: "6.7 The sum and substance of the above rulings is that a notice issued in the name of a dead person is not a valid notice. Further, in order to undertake proceedings in respect of a deceased per…

M/S. Ashok Leyland Ltd., Chennai vs. DCIT, Corporate Circle-1(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 602/CHNY/2025[2017-18]Status: DisposedITAT Chennai29 Jul 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 143(2)Section 143(3)Section 148

…आयकर अपीलीय अिधकरण, ‘ए’ "यायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH: CHENNAI "ी एबी टी. वक", "ाियक सद" एवं एवं एवं एवं "ी जगदीश, लेखा सद" के सम" BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND SHRI JAGADISH, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.602/Chny/2025 िनधा"रणवष"/Assessment Year: 2017-18 v. M/s. Ashok Leyland Ltd., The DCIT, No.1, Sardar Patel Road, Corporate Circle-1(1), Guindy, Chennai-600 032. Chennai. [PAN: AAACA 4651 L] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant by Mr.R. Vijayaraghavan, Advocate : ""यथ" क" ओर से /Respondent by Mr.A.T. Krishnamoorthy, JC…

DCIT Circle-52(1), Income Tax vs. Pranav Gupta, Legal Heir of Late Sh. Vijay Kumar Gupta, New Delhi

ITA 2192/DEL/2023[2009-10]Status: DisposedITAT Delhi20 Jun 2025AY 2009-10

Bench: Smt. Annapurna Gupta & Ms. Madhumita Roydcit, Cir-52(1) Vs. Sh. Pranav Gupta, 1405, 14Th Floor, E-2, Legal Heir Of Late Sh. Vijay Block, Civic Centre, Kumar Gupta, 11, Darya Delhi- 110002 Ganj, New Delhi- 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaipg0797N Appellant .. Respondent

For Appellant: Sh. S. Krishnan, Adv. &For Respondent: Dr. Maninder Kaur, Sr. DR

Section 143(1)Section 147Section 148

…s. ITO, reported in 2018 (6) TMI 760. He has further relied upon the judgment passed by the Hon’ble Apex Court in the matter of PCIT vs. Maruti Suzuki India Ltd, reported in 416 ITR 613 and in the case of Mahagun Realtors Private Limited, reported in(2022) 443 ITR 194(SC). In the absence of notice under Section 148 of the Act validly served either on the original assessee Shri Vijay Kumar Gupta when he was alive or on the deemed assessee being the legal heir of the assessee, the appellant before us renders the assumption of jurisdiction as invalid and therefore, liable to be quashed as prayed by the ld AR be…