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“amalgamation”

Mergers & RestructuringSection 2(1B)Section 2(1B)1,456 judgments

RAMESHKUMAR KARSANBHAI PATEL,SURAT vs. ITO, WARD 2(3)(5), SURAT

Accordingly the estimated addition made of Rs.35,166/-[0.5% of 70,33,182/-] by the AC invoking provision of section 69C of the I.T Act stand deleted. Thus this ground is allowed

ITA 669/SRT/2025[2015-16]Status: DisposedITAT Surat09 Apr 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 10(38)Section 115Section 115BSection 250Section 68Section 69C

Rs.3,00,000/- by purchasing shares of Conart Traders Ltd. from Santoshima Tradelinks Ltd. through banking channels. Subsequently, pursuant to a scheme of amalgamation approved by the Hon’ble Bombay High Court, Conart Traders Ltd. merged with Sunrise Asian Ltd., and the assessee received equivalent shares of Sunrise Asian

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

assessment order passed by the assessing officer in the name of non-existent entity, being HCL Infinet Ltd., which stood amalgamated with HCL Infosystems Ltd., and consequently ceased to exist, is illegal, without jurisdiction and void-ab-initio. 2.2 That the CIT(A) erred on facts ... thus ceases to exist after the said date. 7. It is settled law that and notice/order passed in the name of a non- existent amalgamating entity is void ab initiation, non-est and bad in law.; further the Courts have held that the said jurisdictional defect is not curable under

VIJAY KOTHARI,INDORE vs. DCIT (CENTRAL)-1, INDORE

ITA 267/IND/2024[2015-16]Status: DisposedITAT Indore20 Mar 2026AY 2015-16
Section 143(3)Section 250

Conart\nheld by assessee as on 01.04.2013.\n(e) The company ‘Conart Traders Ltd.” [“Conart”] and one more company\nnamed 'Santoshine Tradelinks Ltd.' got amalgamated into 'Sunrise\nAsian Ltd.' [\"Sunrise”] under a scheme of amalgamation approved by\nHon'ble Bombay High Court dated 22.03.2013. Copy of order of\nHon ... High Court is placed at Pages 8-13 of Paper-Book-I.\n(f) Consequent upon such amalgamation, the assessee received 6,000\nshares of Sunrise in lieu of original 6,000 shares of Conart.\nAccordingly, in the Demat A/c of assessee, there is a debit entry of\nPage

COROMANDEL INTERNATIONAL LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(2), HYDERABAD

In the result the appeal of the assessee is partly allowed for statistical purposes

ITA 738/HYD/2025[2015-2016]Status: DisposedITAT Hyderabad18 Mar 2026AY 2015-2016

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.738/Hyd/2025 ("नधा"रणवष"/ Assessment Year:2015-16) Coromandel International Vs. Dcit, Limited, Circle-2(2), Hyderabad. Hyderabad. Pan: Aaacc7852K (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Sp Chidambaram, Advocate Assessee Represented By राज"वका""त"न"ध"व/ : Ms. U. Mini Chandran, Cit-Dr Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 02/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 18/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Coromandel International Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 24/02/2025 For The Assessment Year (“A.Y.”) 2015-16. Page 1 Of 17 Coromandel International Limited Vs. Dcit 2. The Assessee Has Raised The Following Grounds Of Appeal:

Section 250Section 32Section 32(1)(ii)Section 35

Appellant to furnish response within 10 days from the date of receipt of issue letter. 2. Non-grant of depreciation on goodwill on amalgamation a. The Ld. CIT has grossly erred in law and on facts in denying the Appellant's claim for depreciation on goodwill arising ... amalgamation of erstwhile companies with the Appellant, merely on the ground that the claim was not made in the return of income and did not form part of the assessment order. b. The Ld. CIT failed to appreciate that the allowance of depreciation is not a matter of discretion

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

In the result, grounds raised by the assessee are dismissed

ITA 3533/DEL/2025[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22
Section 143(1)Section 143(3)Section 263Section 40A(2)

order was passed on 15.12.2022\n(ii) The notice u/s 263 was issued on 12.12.2023\n(iii) Scheme of amalgamation was sanctioned vide order dated 15.01.2024\n(iv) The amalgamation effective date was effective from 01.014.2022.\n(v) The assessee informed the above development to the Ld PCIT ... notice issued by Ld PCIT on 12.12.2023 when the scheme of amalgamation was not yet sanctioned and the proceedings are initiated in the old name of the assessee, which is as per law. The scheme of amalgamation was subsequently approved by the Regional Director, which the assessee had informed

SHALBY LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-4(1)(1), AHMEDABAD

In the result, the appeal of the assessee is dismissed

ITA 1005/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad16 Mar 2026AY 2015-16

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2015-16

For Appellant: Shri Aseem Thakkar, A.RFor Respondent: Shri R P Rastogi, CIT-D.R
Section 143(3)Section 56(2)(ib)Section 56(2)(vii)Section 56(2)(viib)Section 68

assessment order is passed in the name of the old name and in fact on 15-09- 2017, the assessee has informed the amalgamation of Shalby Surat Hospital Pvt. Ltd. which amalgamated with Shalby Ltd. to the Assessing Officer. Therefore, the Assessing Officer submitted that the assessment itself ... that the assessee in the proceedings before the Assessing Officer has deliberately chosen the name of the earlier company i.e. NSH Surat instead of amalgamating company i.e. Shalby Ltd. Thus, the Assessing Officer was under bonafide impression despite in which that the assessee is continuing with the name of Shalby

ESCORTS LTD.,FARIDABAD vs. ADDL.CIT, SPECIAL RANGE-3, NEW DELHI

Appeal is allowed

ITA 7394/DEL/2019[2016-17]Status: DisposedITAT Delhi13 Mar 2026AY 2016-17
Section 143(3)

dues of\nKPM as it was facing a lot of problems with IDBI. We find that\nHon'ble Apex Court in the case of Amalgamation Pvt. Ltd. (supra),\nwherein it is held that one company SSM, was originally a\nsubsidiary of A, which was a subsidiary of the assessee-company

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3991/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR
Section 143(3)Section 35Section 41(1)Section 801C

Whether the Ld. CIT(A) erred in law in allowing deduction under section 32AC in respect of capital expenditure incurred by the amalgamating company prior to amalgamation, ignoring the specific condition that such deduction is allowable only to the entity which acquired and installed the plant and machinery during ... investments. In this regard, ld. Assessing Officer noted that assessee had claimed deduction u/s.32AC in respect of plant and machinery of amalgamating company, i.e., Glenmark Generics Ltd. (GGL). According to him, GGL was a separate legal entity before 01.04.2014. Deduction with respect to plant and machinery acquired and installed

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3971/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Mar 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR
Section 143(3)Section 35Section 41(1)Section 801C

Whether the Ld. CIT(A) erred in law in allowing deduction under section 32AC in respect of capital expenditure incurred by the amalgamating company prior to amalgamation, ignoring the specific condition that such deduction is allowable only to the entity which acquired and installed the plant and machinery during ... investments. In this regard, ld. Assessing Officer noted that assessee had claimed deduction u/s.32AC in respect of plant and machinery of amalgamating company, i.e., Glenmark Generics Ltd. (GGL). According to him, GGL was a separate legal entity before 01.04.2014. Deduction with respect to plant and machinery acquired and installed

JCIT, (OSD), CIRCLE 1(1), RAIPUR, RAIPUR vs. MAHENDRA KUMAR GUPTA HUF, RAIPUR, RAIPUR

In the result, appeal of the Revenue is allowed for statistical purposes

ITA 131/RPR/2026[2011-12]Status: DisposedITAT Raipur10 Mar 2026AY 2011-12

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.131/Rpr/2026 "नधा"रण वष" /Assessment Year : 2011-12 The Joint Commissioner Of Income Tax (Osd), Circle-1(1), Raipur (C.G.)

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 133(6)Section 147

copy of balance sheet for the F. Y. 2008-09 is at (PB 3) D) On 06.10.2010 Swamim Papers and Traders Private Limited amalgamated with Konark Commerce and Industries limited (PB 144-165) High court of sanctioned the proposed scheme of amalgamation. (PB 148)." In view of the above ... transactions through a remand report. That further, the Ld. CIT(Appeals)/NFAC has simply stated that since Swarnim Papers and Traders Private Limited amalgamated with Konark Commerce and Industries Limited vide an amalgamation order of the Hon’ble High Court of Calcutta, therefore, the addition was deleted. However, this

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. OASYS CYBERMATICS PVT LTD, CHENNAI

In the result, the appeal filed by the Revenue is dismissed

ITA 3102/CHNY/2025[2016-17]Status: DisposedITAT Chennai09 Mar 2026AY 2016-17

Bench: MS. PADMAVATHY S (Accountant Member), SHRI MANU KUMAR GIRI (Judicial Member)

For Appellant: Mr. ARV Srinivasan, CIT for Mr. Bipin C. N., CITFor Respondent: Mr. Ravi Kannan &
Section 143(2)Section 143(3)Section 147Section 148Section 36(1)(va)Section 5(3)

contribution to PF/ESI – Rs.0.52 crore 6. The Assessing Officer observed that the assessee had claimed depreciation on intangible assets including goodwill arising out of amalgamation. According to the Assessing Officer, such claim was not allowable in the facts and circumstances of the case and accordingly a sum of Rs.8.93 crore

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

appellate order passed by the Ld. CIT(A) is wrong as it has upheld the assessment order based on non-existing company (amalgamating company). 3. The facts in brief are that the assessee filed return of income on 28.09.2012 declaring total income at Rs. ‘Nil’. Thereafter, the case ... order of Ld.CIT(A) upholding the assessment order which has been passed on non existing entity as the company M/s Atlantic Vintrade Pvt.Ltd. was amalgamated with AMPI Finance Limited vide order of the Hon’ble NCLT dated 08.02.2018 with the appointed date of amalgamation being 5 Ampi Finance Limited

DEPUTY COMMISSIONER OF INCOME TAX , CHENNAI vs. OLYMPIA TECH PARK (CHENNAI) PRIVATE LIMITED , CHENNAI

In the result, the appeals of the Revenue for AY 2014-15 & 2015-16

ITA 3084/CHNY/2025[2015-16]Status: DisposedITAT Chennai03 Mar 2026AY 2015-16

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita Nos.3081 & 3084/Chny/2025 िनधा#रण वष# /Assessment Years: 2014-15 & 2015-16

For Appellant: Mr. Ajith Kumar Choradia, C.A ()For Respondent: Mr. Bipin C.N, CIT
Section 143(3)Section 250Section 80I

capital contribution. As per provisions of section 80IA(12) of the Act, if the undertaking is transferred and said transfer is not by amalgamation or demerger, the benefit shall be available to the transferee undertaking. Unlike section 80IA(4)(v) of the Act, which stipulates conditions on formation of assessee ... concept of deduction and as per said circular, if an undertaking is transferred to another undertaking other than by way of amalgamation and demerger and in other cases, the transferee undertaking shall be eligible for deduction for remaining unexpired period. Therefore, we are of the considered view that the ground

DEPUTY COMMISSIONER OF INCOME TAX , CHENNAI vs. OLYMPIA TECH PARK (CHENNAI) PRIVATE LIMITED , CHENNAI

In the result, the appeals of the Revenue for AY 2014-15 & 2015-16

ITA 3081/CHNY/2025[2014-15]Status: DisposedITAT Chennai03 Mar 2026AY 2014-15

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita Nos.3081 & 3084/Chny/2025 िनधा#रण वष# /Assessment Years: 2014-15 & 2015-16

For Appellant: Mr. Ajith Kumar Choradia, C.A ()For Respondent: Mr. Bipin C.N, CIT
Section 143(3)Section 250Section 80I

capital contribution. As per provisions of section 80IA(12) of the Act, if the undertaking is transferred and said transfer is not by amalgamation or demerger, the benefit shall be available to the transferee undertaking. Unlike section 80IA(4)(v) of the Act, which stipulates conditions on formation of assessee ... concept of deduction and as per said circular, if an undertaking is transferred to another undertaking other than by way of amalgamation and demerger and in other cases, the transferee undertaking shall be eligible for deduction for remaining unexpired period. Therefore, we are of the considered view that the ground

ITO, PHALODI vs. VARSHA MILLS, KHICHAN

In the result, the appeal of the Revenue is dismissed

ITA 197/JODH/2024[2017-18]Status: DisposedITAT Jodhpur26 Feb 2026AY 2017-18

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Bleito Varsha Mills, Khichan Phalodi E-51, Industrial Estate, Khichan, Phalodi, Jodhpur – 342308 Pan No.: Aaifv 9450 D Assessee By Shri Kapil Hirani, Advocate (Virtual) Smt. Runi Pal – Cit-Dr (Virtual) Revenue By Date Of Hearing 29.01.2026. Date Of Pronouncement 26.02.2026. Order Dr. Mitha Lal Meena, A.M.: This Appeal Is Filed By Revenue Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter Referred To As Nfac/Cit(A)] Dated 07.02.2024 With Respect To Assessment Year 2017-18 Challenging Therein Decision Of The Ld. Cit(A) In Deleting The Addition Made U/S 69A On Account Of Un-Explained Cash Deposits During Demonetization Period & By Invoking Provisions Of Section 145(3) Of The Act.

Section 145(3)Section 69A

justification on the part of the assessee to have reassessed the value of the inventory and thereafter written off the items acquired on the amalgamation of M/s Sequent Scientific Ltd, and valued the same as per its conventional method of valuation at the lower of cost or net realisable value

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BRGD SPONGE & IRON PRIVATE LIMITED , KOLKATA

In the result, the appeal of the Revenue is dismissed and the appeal\nof the assessee is allowed

ITA 1966/KOL/2025[2016-17]Status: DisposedITAT Kolkata26 Feb 2026AY 2016-17
Section 115JSection 132(1)Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 148ASection 68

interalia\nengaged in the business of trading of TMT Bars etc. M/s Balgopal Tie\nup Pvt Ltd, a private limited company was amalgamated with the\nassessee company vide order of National Company Law Tribunal,\nKolkata Bench dated 20.09.2022, copy of which is available at page\nno.38 ... bogus and Rs. 2,30,00,000/- was\nadded on account of sale of investments by the assessee of unlisted\nequity shares by the amalgamating company M/S Balgopal Tie-up\nPvt Ltd. The said amalgamation was effected vide order of the\nNational Company Law Tribunal, Kolkata Bench vide order dated

BRGD SPONGE & IRON PVT. LTD.,,KOLKATA vs. DCIT, CENTRAL CIRCLE 4(3),, KOLKATA

In the result, the appeal of the Revenue is dismissed and the appeal\nof the assessee is allowed

ITA 1403/KOL/2025[2016-2017]Status: DisposedITAT Kolkata26 Feb 2026AY 2016-2017
Section 115JSection 132(1)Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 148ASection 68

interalia\nengaged in the business of trading of TMT Bars etc. M/s Balgopal Tie\nup Pvt Ltd, a private limited company was amalgamated with the\nassessee company vide order of National Company Law Tribunal,\nKolkata Bench dated 20.09.2022, copy of which is available at page\nno.38 ... account of sale of investments by the assessee of unlisted\nequity shares by the\namalgamating company M/S Balgopal Tie-up\nPvt Ltd. The said amalgamation was effected vide order of the\nNational Company Law Tribunal, Kolkata Bench vide order dated\n20.09.2022.\n3.2.\nThe Id counsel of the assessee submitted that

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)

section 43(6)(c) and section 55(2)(a)(ii) which established that Depreciation cannot be claimed on goodwill arising out of amalgamation under the existing provision of the Income-tax Act." 3) "The Revenue craves leave to add/alter/armed and/or substitute any or all of the grounds of appeal ... declaring total income of Rs.1,42,588/-. The entity has undergone a series of restructuring events: Unicorn Packers Pvt. Ltd. was amalgamated with Urmin Marketing Pvt. Ltd. with appointed date 01.04.2014 pursuant to a scheme of amalgamation approved by the Hon’ble Gujarat High Court vide order dated 27.07.2015; thereafter

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)

section 43(6)(c) and section 55(2)(a)(ii) which established that Depreciation cannot be claimed on goodwill arising out of amalgamation under the existing provision of the Income-tax Act." 3) "The Revenue craves leave to add/alter/armed and/or substitute any or all of the grounds of appeal ... declaring total income of Rs.1,42,588/-. The entity has undergone a series of restructuring events: Unicorn Packers Pvt. Ltd. was amalgamated with Urmin Marketing Pvt. Ltd. with appointed date 01.04.2014 pursuant to a scheme of amalgamation approved by the Hon’ble Gujarat High Court vide order dated 27.07.2015; thereafter

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)

section 43(6)(c) and section 55(2)(a)(ii) which established that Depreciation cannot be claimed on goodwill arising out of amalgamation under the existing provision of the Income-tax Act." 3) "The Revenue craves leave to add/alter/armed and/or substitute any or all of the grounds of appeal ... declaring total income of Rs.1,42,588/-. The entity has undergone a series of restructuring events: Unicorn Packers Pvt. Ltd. was amalgamated with Urmin Marketing Pvt. Ltd. with appointed date 01.04.2014 pursuant to a scheme of amalgamation approved by the Hon’ble Gujarat High Court vide order dated 27.07.2015; thereafter

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