What is PCIT v. Maruti Suzuki India Ltd. authority for?

An assessment order framed against a company that has ceased to exist due to amalgamation is invalid and non-est in law. Jurisdictional issues concerning the assessment of a non-existent entity can be raised as an additional ground before the Income Tax Appellate Tribunal.

How many judgments cite PCIT v. Maruti Suzuki India Ltd.?

303 judgments on BharatTax cite PCIT v. Maruti Suzuki India Ltd. (416 ITR 613), spanning 2019 to 2026.

Which sections of the Income Tax Act does PCIT v. Maruti Suzuki India Ltd. come up under?

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

PCIT v. Maruti Suzuki India Ltd. (416 ITR 613)

HCL INFOSYSTEMS LTD,NEW DELHI vs. DCIT CIRCLE-25(2), NEW DELHI

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

ITA 8055/DEL/2019[2006-07]Status: DisposedITAT Delhi09 Apr 2026AY 2006-07

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarhcl Infosystems Ltd Vs. Dcit 806, 96, Nehru Place, Circle-25(2) South Delhi 110019 New Delhi "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaach 2420 C Appellant .. Respondent

For Appellant: Sh. Deepesh Jain, Adv. &For Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 143(2)Section 143(3)Section 144Section 250Section 68

…n-est and bad in law.; further the Courts have held that the said jurisdictional defect is not curable under sections 154 and/or 292BB of the Act. 8. Reference in this regard may be made to the following judgements:  PCIT v. Maruti Suzuki India Ltd: [2019] 416 ITR 613 (SC)  CIT v. Spice Enfotainment Ltd.: 247 CTR 500 (Del.) - Department's appeal (batch) dismissed by apex Court on 2.11.2017  Sterlite Technologies Ltd. v. DCIT: (2024) 462 ITR 457 (Bom)- (affirmed by the Hon'ble Apex Court in (2024) 462 ITR 462)  International Hospital Ltd. v. DCIT: [2024] 167 taxmann.com 317 (Delhi)[26-09-2024]  BDR Builders…

LATE JANKIDEVI NANDLAL JAISWAL THROUGH LEGAL HEIR SHRI AMIT MOHANLAL JAISWAL,NAGPUR vs. ITO WARD-4(4), NAGPUR

In the result, it is directed that the order passed under section 263 be set aside

ITA 238/NAG/2024[2015-16]Status: DisposedITAT Nagpur27 Mar 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Khettra Mohan Roylate Jankidevi Nandlal Ito, Ward – 4(4), Nagpur Jaiswal Through Lr Amit Vs Mohanlal Jaiswal, 3/14, Balabhaupeth, Panchpaoli Nagpur-440017 Pan : Adgpj 9652 C Assessee Respondent Assessee By : Shri Himesh Demble, Ca Revenue By : Shri Pankaj Kumar, Cit-Dr Date Of Hearing : 24.02.2026 Date Of Pronouncement : 27.03.2026

For Appellant: Shri Himesh Demble, CAFor Respondent: Shri Pankaj Kumar, CIT-DR

Section 147Section 148Section 159(3)Section 263

…lity, therefore, consequential proceedings and orders passed thereon were to be quashed and set aside. Further, the following decisions also support the above proposition of law: ➢ Pr. CIT v. Maruti Suzuki India Ltd. [2019] 107 taxmann.com 375/265 Taxman 515/416 ITR 613 (SC); ➢ Krishnaawatar Kabra v. ITO [2022] 140 taxmann.com 423 (Gujarat); ➢ Rajender Kumar Sehgal v. ITO [2019] 101 taxmann.com 233/260 Taxman 412/414 ITR 286 (Delhi); ➢ Sandeep Chopra v. Pr. CIT [2023] 149 taxmann.com 225/292 Taxman 269 (Jharkhand); ➢ SavitaKapila v. Asstt. CIT [2020] 118 taxmnann.com 46/273 Taxman 148/426 ITR 502 (Delhi); 11. Ac…

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

ITA 3533/DEL/2025[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 143(1)Section 143(3)Section 263Section 40A(2)

…in the name and PAN of a non-existent entity is, in view of the settled law, illegal and bad in law. Reliance in this regard is placed on the following decisions: Saraswati Industrial Syndicate Ltd. v. CIT: 186 ITR 278 (SC) PCIT vs. Maruti Suzuki India Ltd.: 416 ITR 613 (SC) PCIT v. Vedanta Ltd.: [2025] 170 taxmann.com 833 (Del) International Hospital Ltd. v. DCIT [2024] 167 taxmann.com 317 (Del) Spice Entertainment Ltd. CST 2012 (280) ELT 43 (Del) PCIT v. Vertex Customer Management India Private Limited: ITA No. 606/2019 (Del) Religare Enterprises Limited v. ACIT: (WP No. 13807/2022) (Del) Pharmazell (India) (P…

MRS. SUREKHA LEGAL REPRESENTATIVE OF LATE SHRI. DEVARAJ,BENGALURU vs. INCOME TAX OFFICER, WARD-7(2)(5), BANGALORE

In the result, appeal filed by the assessee is allowed

ITA 2419/BANG/2025[2018-19]Status: DisposedITAT Bangalore06 Mar 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2018-19 Mrs. Surekha (Legal Representative Of Late Shri Devaraj, Since Dead) No.112, 1St Main, Ramarao Layout Vs. Ito Bsk 3Rd Phase, 3Rd Stage Ward 7(2)(5) Bengaluru 560 085 Bengaluru Pan No :Asvps2939R Appellant Respondent Appellant By : Sri Balachandran, A.R. Respondent By : Sri N. Balusamy, D.R. Date Of Hearing : 17.02.2026 Date Of Pronouncement : 06.03.2026

For Appellant: Sri Balachandran, A.RFor Respondent: Sri N. Balusamy, D.R

Section 143(2)Section 250

…ITA No.2419/Bang/2025 Mrs. Surekha (Legal Rep. of Late Shri Devaraj, since dead), Bengaluru IN THE INCOME TAX APPELLATE TRIBUNAL “A’’BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER Assessment Year : 2018-19 Mrs. Surekha (Legal Representative of Late Shri Devaraj, since dead) No.112, 1st Main, Ramarao Layout Vs. ITO BSK 3rd Phase, 3rd Stage Ward 7(2)(5) Bengaluru 560 085 Bengaluru PAN NO :ASVPS2939R APPELLANT RESPONDENT Appellant by : Sri Balachandran, A.R. Respondent by : Sri N. Balusamy, D.R. Date of Hearing : 17.02.2026 Date of Pronouncement : 06.03.2026 O…

AMPI FINANCE LIMITED,KOLKATA vs. I.T.O., WARD-4(3), KOLKATA

Appeal of the assessee is allowed

ITA 2831/KOL/2025[2012-13]Status: DisposedITAT Kolkata05 Mar 2026AY 2012-13

Bench: the Bench that the re-opening of

Section 143(3)Section 144Section 147Section 148Section 148(2)Section 250Section 69C

…possible to treat the two companies as partners or jointly liable in respect of their liabilities and assets." 10. The case of the assessee is covered by the decision of Hon’ble Apex Court in the case of PCIT Vs. Maruti Suzuki India Limited reported in (2019) 416 ITR 613, wherein it has been held as under: “The assessee SPIL was a joint venture between SMC and MSIL. It filed its return declaring certain taxable income. The return was processed under section 143(1) and then picked up for scrutiny. Notices under section 143(2) were issued. Subsequently, the High Court passed an order approving the Scheme of Amalga…

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 898/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2020-21

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

…he time the said company ceased to exist as the same was converted into a limited liability partnership-firm. The Ld. CIT(A), in this respect, has relied upon the decision of the Hon’ble Supreme Court in the case of Pr. CIT vs. Maruti Suzuki India Ltd. (2019) 416 ITR 613, wherein, the Hon’ble Supreme Court held that the assessment order passed in the name of non-existing company would be without jurisdiction and nullity. The Ld. CIT(A) observed that in this case also, the assessee-company namely Unicorn Packings Pvt.Ltd. has had ceased to exist when the notice u/s.143(2) was issued and even the assessment has bee…

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD, AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 897/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2018-19

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

…he time the said company ceased to exist as the same was converted into a limited liability partnership-firm. The Ld. CIT(A), in this respect, has relied upon the decision of the Hon’ble Supreme Court in the case of Pr. CIT vs. Maruti Suzuki India Ltd. (2019) 416 ITR 613, wherein, the Hon’ble Supreme Court held that the assessment order passed in the name of non-existing company would be without jurisdiction and nullity. The Ld. CIT(A) observed that in this case also, the assessee-company namely Unicorn Packings Pvt.Ltd. has had ceased to exist when the notice u/s.143(2) was issued and even the assessment has bee…

ACIT CC-1(3), AHMEDABAD, AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 896/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

…he time the said company ceased to exist as the same was converted into a limited liability partnership-firm. The Ld. CIT(A), in this respect, has relied upon the decision of the Hon’ble Supreme Court in the case of Pr. CIT vs. Maruti Suzuki India Ltd. (2019) 416 ITR 613, wherein, the Hon’ble Supreme Court held that the assessment order passed in the name of non-existing company would be without jurisdiction and nullity. The Ld. CIT(A) observed that in this case also, the assessee-company namely Unicorn Packings Pvt.Ltd. has had ceased to exist when the notice u/s.143(2) was issued and even the assessment has bee…

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING PRIVATE LIMITED, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 895/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

…he time the said company ceased to exist as the same was converted into a limited liability partnership-firm. The Ld. CIT(A), in this respect, has relied upon the decision of the Hon’ble Supreme Court in the case of Pr. CIT vs. Maruti Suzuki India Ltd. (2019) 416 ITR 613, wherein, the Hon’ble Supreme Court held that the assessment order passed in the name of non-existing company would be without jurisdiction and nullity. The Ld. CIT(A) observed that in this case also, the assessee-company namely Unicorn Packings Pvt.Ltd. has had ceased to exist when the notice u/s.143(2) was issued and even the assessment has bee…

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 894/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

…he time the said company ceased to exist as the same was converted into a limited liability partnership-firm. The Ld. CIT(A), in this respect, has relied upon the decision of the Hon’ble Supreme Court in the case of Pr. CIT vs. Maruti Suzuki India Ltd. (2019) 416 ITR 613, wherein, the Hon’ble Supreme Court held that the assessment order passed in the name of non-existing company would be without jurisdiction and nullity. The Ld. CIT(A) observed that in this case also, the assessee-company namely Unicorn Packings Pvt.Ltd. has had ceased to exist when the notice u/s.143(2) was issued and even the assessment has bee…

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 893/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

…he time the said company ceased to exist as the same was converted into a limited liability partnership-firm. The Ld. CIT(A), in this respect, has relied upon the decision of the Hon’ble Supreme Court in the case of Pr. CIT vs. Maruti Suzuki India Ltd. (2019) 416 ITR 613, wherein, the Hon’ble Supreme Court held that the assessment order passed in the name of non-existing company would be without jurisdiction and nullity. The Ld. CIT(A) observed that in this case also, the assessee-company namely Unicorn Packings Pvt.Ltd. has had ceased to exist when the notice u/s.143(2) was issued and even the assessment has bee…

JADAGADDER PAKKERAPPA, LEGAL HEIR SAROJAMMA,SHIKARIPURA vs. INCOME TAX OFFICER, WARD-1 & TPS,, SHIMOGA

In the result, appeal filed by the assessee is allowed

ITA 1406/BANG/2025[2016-17]Status: DisposedITAT Bangalore25 Feb 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2016-17

For Appellant: Sri Varun Bhat, A.RFor Respondent: Sri Balusamy N., D.R

Section 142(1)Section 144Section 147Section 148Section 15Section 250

…ITA No.1406/Bang/2025 Jadagadder Pakkerappa, Shikaripura IN THE INCOME TAX APPELLATE TRIBUNAL “A’’BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER Assessment Year : 2016-17 Jadagadder Pakkerappa Legal Heir: Sarojamma Tagagunda (Post) ITO Shikaripura (Tq) Vs. Ward 1 & TPS Karnataka 577 428 Shimoga PAN NO :BAXPP4539H APPELLANT RESPONDENT Appellant by : Sri Varun Bhat, A.R. Respondent by : Sri Balusamy N., D.R. Date of Hearing : 01.12.2025 Date of Pronouncement : 26.02.2026 O R D E R PER KESHAV DUBEY, JUDICIAL MEMBER: This appeal at the instance of the asse…

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

…CIT(A), the Assessee has filed the appeal before the Tribunal. 5. Rival contentions were heard and the submissions made have been examined. Relying upon the decision in the case of Pr. CIT v. Maruti Suzuki India Ltd. [2019] 107 taxmann.com 375/265 Taxman 515/416 ITR 613 (SC), it was contended by the Ld. AR that Bihar Kshetriya Gramin bank (RRB) and Samastipur Kshetriya Gramin Bank had amalgamated into a single regional rural bank called as “Bihar Gramin Bank” vide notification No. S.O. 2971(E) dated 21.12.2012 and was not in existence on the date of issue of the notice. However, it has been held in the case of P…

KAMUTHI SOLAR POWER LIMITED (MERGED WITH ADANI GREEN ENERGY TWENTY -THREE LTD.),AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, appeal of the assessee is allowed

ITA 1242/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalkamuthi Solar Power Limited Vs. Principal Commissioner Of (Merged With Adani Green Income-Tax, Energy Twenty Three Ltd.), Ahmedabad-1 Adani House, Nr. Mithakhali Six Roads, Ahmedabad-380009 [Pan :Aafck 8399 E] (Appellant) .. (Respondent) Appellant By : Shri Biren Shah, Ar Respondent By: Shri R.P. Rastogi, Cit-Dr Date Of Hearing 10.12.2025 Date Of Pronouncement 13.02.2026

For Appellant: Shri Biren Shah, ARFor Respondent: Shri R.P. Rastogi, CIT-DR

Section 115BSection 143(3)Section 144BSection 263

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER Kamuthi Solar Power Limited Vs. Principal Commissioner of (Merged with Adani Green Income-tax, Energy Twenty Three Ltd.), Ahmedabad-1 Adani House, Nr. Mithakhali Six Roads, Ahmedabad-380009 [PAN :AAFCK 8399 E] (Appellant) .. (Respondent) Appellant by : Shri Biren Shah, AR Respondent by: Shri R.P. Rastogi, CIT-DR Date of Hearing 10.12.2025 Date of Pronouncement 13.02.2026 O R D E R PER DR. B.R.R. KUMAR, VICE-PRESIDENT:- This appeal has been filed by the assessee against th…

HAPPY SUPPLIERS PVT. LTD., (MERGED WITH RISHI SECURITIES & FINANCE PRIVATE LIMITED),KOLKATA vs. ACIT, CENTRAL CIRCLE 3(1),, KOLKATA

In the result, both the captioned appeals of the assessee are allowed

ITA 2578/KOL/2025[2021-2022]Status: DisposedITAT Kolkata12 Feb 2026AY 2021-2022

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2577 & 2578/Kol/2025 (Assessment Years: 2016-17 & 2021-22) Happy Suppliers Pvt. Ltd (Merged With Rishi Securities & Finance Private Limited)……….……….……Appellant Octavius Centre, 1St Floor, 15B, Hemant Basu Sarani, Kol-1. [Pan: Aabch9212M] Vs. Acit, Central Circle-3(1), Kolkata….……………………….....……...…..…..Respondent Appearances By: Shri S. K. Tulsiyan, Advocate & Lata Goyal, Ca, Appeared On Behalf Of The Appellant. Shri Sandip Sarkar, Jcit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 28, 2026 Date Of Pronouncing The Order : February 12, 2026 Order Per Pradip Kumar Choubey: Both The Present Appeals Have Been Preferred By The Assessee Against Separate Orders Dated 08.09.25 & 28.08.2025 Of The Commissioner Of Income Tax (Exemption)-21, Kolkata [Hereinafter Referred To As ‘Cit(E)’] U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since Both The Appeals Relate To The Assessee & Facts Are Similar, Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Relevant A.Y Declaring Nil Income. A Search & Seizure

Section 132Section 143(2)Section 147Section 148Section 250Section 56(2)Section 56(2)(x)Section 69Section 69A

…ce of the department so the department was very much aware of the amalgamation of Happy Suppliers Pvt. Ltd. He has cited following case laws: i. Saraswati Industrial Syndicate Ltd. vs. CIT [1990] 186 ITR 278 (SC) ii. PCIT vs. Maruti Suzuki India Ltd. [2019] 416 ITR 613 (SC) 5. Contrary to that, the ld. DR supports the impugned order thereby submitting that this ground has not been taken by the assessee before the lower authorities and further before the ld. CIT(A), there was non- cooperation, hence, at this stage, the assessee cannot be permitted to raise the same. 6. Upon hearing the counsels of the respecti…

HAPPY SUPPLIERS PVT. LTD., (MERGED WITH RISHI SECURITIES & FINANCE PRIVATE LIMITED),KOLKATA vs. ACIT, CENTRAL CIRCLE 3(1),, KOLKATA

In the result, both the captioned appeals of the assessee are allowed

ITA 2577/KOL/2025[2016-2017]Status: DisposedITAT Kolkata12 Feb 2026AY 2016-2017

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2577 & 2578/Kol/2025 (Assessment Years: 2016-17 & 2021-22) Happy Suppliers Pvt. Ltd (Merged With Rishi Securities & Finance Private Limited)……….……….……Appellant Octavius Centre, 1St Floor, 15B, Hemant Basu Sarani, Kol-1. [Pan: Aabch9212M] Vs. Acit, Central Circle-3(1), Kolkata….……………………….....……...…..…..Respondent Appearances By: Shri S. K. Tulsiyan, Advocate & Lata Goyal, Ca, Appeared On Behalf Of The Appellant. Shri Sandip Sarkar, Jcit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 28, 2026 Date Of Pronouncing The Order : February 12, 2026 Order Per Pradip Kumar Choubey: Both The Present Appeals Have Been Preferred By The Assessee Against Separate Orders Dated 08.09.25 & 28.08.2025 Of The Commissioner Of Income Tax (Exemption)-21, Kolkata [Hereinafter Referred To As ‘Cit(E)’] U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since Both The Appeals Relate To The Assessee & Facts Are Similar, Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Relevant A.Y Declaring Nil Income. A Search & Seizure

Section 132Section 143(2)Section 147Section 148Section 250Section 56(2)Section 56(2)(x)Section 69Section 69A

…ce of the department so the department was very much aware of the amalgamation of Happy Suppliers Pvt. Ltd. He has cited following case laws: i. Saraswati Industrial Syndicate Ltd. vs. CIT [1990] 186 ITR 278 (SC) ii. PCIT vs. Maruti Suzuki India Ltd. [2019] 416 ITR 613 (SC) 5. Contrary to that, the ld. DR supports the impugned order thereby submitting that this ground has not been taken by the assessee before the lower authorities and further before the ld. CIT(A), there was non- cooperation, hence, at this stage, the assessee cannot be permitted to raise the same. 6. Upon hearing the counsels of the respecti…

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

…254 taxman 390 (SC) holding that it is a mere procedural defect or curable mistake u/s 292(B) of the Act. Ld. AR submitted that the lower authorities have failed to consider the decision of the Hon’ble Apex Court in the case of Maruti Suzuki India Ltd. (2019) 416 ITR 613 (SC) which was subsequently followed by various High Courts and the Tribunals. The Ld. AR distinguished the facts of the case in the Sky Light Hospitality LLP v. Asstt. CIT (Supra) relied upon by Ld. CIT(A). The ld. AR relied on the catena of decisions in support of the assessee’s contention that the assessment order passed in the name of the…

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

…254 taxman 390 (SC) holding that it is a mere procedural defect or curable mistake u/s 292(B) of the Act. Ld. AR submitted that the lower authorities have failed to consider the decision of the Hon’ble Apex Court in the case of Maruti Suzuki India Ltd. (2019) 416 ITR 613 (SC) which was subsequently followed by various High Courts and the Tribunals. The Ld. AR distinguished the facts of the case in the Sky Light Hospitality LLP v. Asstt. CIT (Supra) relied upon by Ld. CIT(A). The ld. AR relied on the catena of decisions in support of the assessee’s contention that the assessment order passed in the name of the…

WORLD RESORTS LIMITED,BANGALORE vs. INCOME TAX OFFICER WARD (4)(1)(4), BANGALORE

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

ITA 1540/BANG/2025[2012-13]Status: DisposedITAT Bangalore28 Jan 2026AY 2012-13

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhailassessment Year : 2012-13

For Appellant: Shri Neelkanth Khandelwal, CAFor Respondent: Shri Subramanian, Jt.CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 68

…IT(A) did not quash the assessment order, but Page 4 of 5 adjudicated on the issue of reopening as well as on the merits of the case. 8. The ld. AR further referred to the decision of the Hon’ble Supreme Court in the case of PCIT v. Maruti Suzuki India Ltd. 416 ITR 613, the decision of the Hon’ble Bombay High Court in the case of PCIT v. Culver Max Entertainment Pvt. Ltd. and Uber India Systems Pvt. Ltd. v. ACIT, 168 taxmann.com 200. 9. The ld. DR vehemently submitted that the assessee though amalgamated, but the ld. AO in the body of the order has clearly recorded that there is an amalgamation of this company…

IYOGI PRIVATE LIMITED,DELHI vs. THE INCOME TAX OFFICER, DELHI

Appeal is allowed

ITA 3254/DEL/2025[2017-18]Status: DisposedITAT Delhi22 Jan 2026AY 2017-18

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI AMITABH SHUKLA (Accountant Member)

Section 144

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER Assessment Year: 2017-18 IYOGI PRIVATE LIMITED, Vs. Income Tax Officer, 178, Golf Links, Ward-12(4), New Delhi New Delhi PAN: AACCI5597B (Appellant) (Respondent) Assessee by Sh. Anil Choudhary, CA Department by Ms. Ankush Kalra, Sr. DR Date of hearing 22.01.2026 Date of pronouncement 22.01.2026 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2017-18, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appea…

PCIT v. Maruti Suzuki India Ltd.

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Judgments citing PCIT v. Maruti Suzuki India Ltd.

HCL INFOSYSTEMS LTD,NEW DELHI vs. DCIT CIRCLE-25(2), NEW DELHI

LATE JANKIDEVI NANDLAL JAISWAL THROUGH LEGAL HEIR SHRI AMIT MOHANLAL JAISWAL,NAGPUR vs. ITO WARD-4(4), NAGPUR

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

MRS. SUREKHA LEGAL REPRESENTATIVE OF LATE SHRI. DEVARAJ,BENGALURU vs. INCOME TAX OFFICER, WARD-7(2)(5), BANGALORE

AMPI FINANCE LIMITED,KOLKATA vs. I.T.O., WARD-4(3), KOLKATA

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD, AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

ACIT CC-1(3), AHMEDABAD, AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING PRIVATE LIMITED, AHMEDABAD

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

JADAGADDER PAKKERAPPA, LEGAL HEIR SAROJAMMA,SHIKARIPURA vs. INCOME TAX OFFICER, WARD-1 & TPS,, SHIMOGA

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

KAMUTHI SOLAR POWER LIMITED (MERGED WITH ADANI GREEN ENERGY TWENTY -THREE LTD.),AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

HAPPY SUPPLIERS PVT. LTD., (MERGED WITH RISHI SECURITIES & FINANCE PRIVATE LIMITED),KOLKATA vs. ACIT, CENTRAL CIRCLE 3(1),, KOLKATA

HAPPY SUPPLIERS PVT. LTD., (MERGED WITH RISHI SECURITIES & FINANCE PRIVATE LIMITED),KOLKATA vs. ACIT, CENTRAL CIRCLE 3(1),, KOLKATA

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

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

WORLD RESORTS LIMITED,BANGALORE vs. INCOME TAX OFFICER WARD (4)(1)(4), BANGALORE

IYOGI PRIVATE LIMITED,DELHI vs. THE INCOME TAX OFFICER, DELHI