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“amalgamation”

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

The decision most relied on for amalgamation is CIT v. Smifs Securities Ltd. (348 ITR 302), cited in 540 judgments on BharatTax.

Leading authorities on amalgamation

CIT v. Smifs Securities Ltd.
348 ITR 302 · 2012 · Supreme Court
540
citing judgments

Goodwill, whether arising from an amalgamation or a slump sale, is an intangible asset eligible for depreciation under Section 32(1) of the Income-tax Act. While the assessee must prove the existence and valuation of such goodwill, it is recognized as a depreciable asset.

PCIT v. Maruti Suzuki India Ltd.
416 ITR 613 · 2019 · Supreme Court
308
citing judgments

A notice issued under section 148 to a non-existent entity, such as an amalgamating company post-merger, is a substantive illegality, rendering assessment proceedings void ab initio. Participation in such proceedings does not estop the assessee from challenging the validity of the notice.

Spice Infotainment Ltd. v. CIT
247 CTR 500 · 2012 · High Court
114
citing judgments

An assessment framed in the name of a company that has ceased to exist due to amalgamation is invalid, even if the amalgamated company participated in the proceedings. Such a defect cannot be cured under section 292B of the Income-tax Act.

PCIT v. Mahagun Realtors Pvt. Ltd.
443 ITR 194 · 2022 · Supreme Court
95
citing judgments

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.

Saraswati Industrial Syndicate Ltd. v. CIT
186 ITR 278 · 1990 · Supreme Court
79
citing judgments

Upon amalgamation, the amalgamating company ceases to exist in the eyes of the law. Therefore, any assessment or proceeding initiated against a non-existent amalgamating company is invalid as it is no longer considered a 'person' under the Income-tax Act.

CIT v. Amalgamations Ltd.
238 ITR 963 · 1998 · High Court
73
citing judgments

An assessment order can be deemed erroneous due to the Assessing Officer's non-application of mind or inadequate inquiry, warranting revision under Section 263. However, the Principal Commissioner of Income Tax must establish the order is both erroneous and prejudicial to the revenue, and cannot use this power merely to direct further inquiries without such a finding.

Additional/Joint/Deputy/Assistant Commissioner of Incometax/Income-tax Officer v. Mylan Laboratories Ltd.
137 Taxmann.com 178 · 2022 · High Court
60
citing judgments

Goodwill arising on amalgamation is entitled to depreciation. This principle is established by multiple High Court decisions.

Beverages 331 ITR 192 (Del) B.Raveendran Pillai v. CIT
237 Taxmann 230 · 2016 · High Court
59
citing judgments

Goodwill arising on amalgamation is an intangible asset qualifying for depreciation under Section 32 of the Income Tax Act.

Judgments citing amalgamation

The Belgaum Manufacturers Co-Op Industrial Estate Ltd, Belagavi vs. Pr. Commissioner of Income Tax, Hubbali

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

ITA 154/PAN/2025[2020-21]Status: DisposedITAT Panaji20 Aug 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.154/Pan/2025 (A.Y.2020-21) The Belgaum Manufactures Vs. Pr.Cit, Co-Op Industrial Estate C.R.Building, Limited, Navanagar, 10 342/690,Udyambag, Hubli-580025, Belgaum-590008, Karnataka. Karnataka Pan .No.Aaaat7254J (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Pramod Y Vaidya.Ar Revenue By Shri.Captain Pradeep Arya.Cit.Dr सुनवाई की तारीख/Date Of Hearing 14.08.2025 घोषणा की तारीख/Date Of 20.08.2025 Pronouncement Order Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Pr. Commissioner Of Income Tax (Pr.Cit) Hubli Passed U/S 263 Of The Act. The Assesse Has Raised The Grounds Of Appeal Challenging The Revision Order Passed By The Pr.Cit Set Aside The Order Passed By The Assessing Officer. 2. The Brief Facts Of The Case Are That, The Assessee Is A Cooperative Society Registered Under Bombay Co-Operative

Section 143(2)Section 143(3)Section 263Section 80PSection 80P(2)(d)

Assessing Officer to decide the aspect/question….” Similar view has been expressed by Hon’ble Madras High Court in the case of CIT Vs. Amalgamations Ltd (238 ITR 963). 9. Considering the ratio of decisions of the Honble Hight courts, it is clear the Pr.CIT before holding the order

Thermo Fisher Scientific India Private Limited, Mumbai vs. The Deputy Commissioner of Income Tax -15(3)(1), Mumbai

In the result, appeal of the assessee is allowed as per our aforesaid

ITA 2847/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Aug 2025AY 2020-21

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.2847/Mum/2025 निर्धारण वर्ष / Assessment Year :2020-21 Thermo Fisher Scientific India Private Limited 403-404, Delphil B Wing, Hiranandani Business Park, Powai Iit, Mumbai-400 076 Pan : Aabct3207A ........अपीलार्थी / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax-15(3)(1), Mumbai ......प्रत्यर्थी / Respondent Assessee By : Shri Vipul Soni Revenue By : Shri Himanshu Joshi, Sr. Dr सुनवाई की तारीख / Date Of Hearing :14.08.2025 घोषणा की तारीख / Date Of Pronouncement : 20.08.2025

For Appellant: Shri Vipul SoniFor Respondent: Shri Himanshu Joshi, Sr. DR
Section 143(3)Section 270ASection 32(1)Section 80G

capital gain tax us 50B in the hand of seller. Where as the according the Assessing officer the acquisitions are in the nature of amalgamation. Before us, the learned counsel has referred to various clauses of business transfer agreement (BTA) in respect of units acquired from GSK and CTPL respectively ... perusal of relevant clauses referred, we find that transaction in both the cases are of slump sale and not, amalgamation as stated by the Assessing Officer. 5.19 The learned Assessing Officer has further relied on the Explanation 7 to Section 43(1) of the Act, to hold that assessee

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

account of alleged interest paid on alleged cash deposits and that too allegedly relating to M/s SRS Buildcon P. Ltd., a company which had amalgamated with the assessee company in the preceding assessment year. 4) That in any case and in any view of the matter, action ... contains replies submitted before AO intimating the fact of merger and the said replies would show that matter was represented by the amalgamated entity i.e., BTL Holding Ltd. Ld. Counsel submitted that PB 1, PB 46 and 53 are copy of 8 ITA Nos.7430/Del/2019 & 3618 to 3620/Del/2018 notice u/s 153A

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

account of alleged interest paid on alleged cash deposits and that too allegedly relating to M/s SRS Buildcon P. Ltd., a company which had amalgamated with the assessee company in the preceding assessment year. 4) That in any case and in any view of the matter, action ... contains replies submitted before AO intimating the fact of merger and the said replies would show that matter was represented by the amalgamated entity i.e., BTL Holding Ltd. Ld. Counsel submitted that PB 1, PB 46 and 53 are copy of 8 ITA Nos.7430/Del/2019 & 3618 to 3620/Del/2018 notice u/s 153A

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

account of alleged interest paid on alleged cash deposits and that too allegedly relating to M/s SRS Buildcon P. Ltd., a company which had amalgamated with the assessee company in the preceding assessment year. 4) That in any case and in any view of the matter, action ... contains replies submitted before AO intimating the fact of merger and the said replies would show that matter was represented by the amalgamated entity i.e., BTL Holding Ltd. Ld. Counsel submitted that PB 1, PB 46 and 53 are copy of notice u/s 153A dated 06.08.2013, copy of notice

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

account of alleged interest paid on alleged cash deposits and that too allegedly relating to M/s SRS Buildcon P. Ltd., a company which had amalgamated with the assessee company in the preceding assessment year. 4) That in any case and in any view of the matter, action ... contains replies submitted before AO intimating the fact of merger and the said replies would show that matter was represented by the amalgamated entity i.e., BTL Holding Ltd. Ld. Counsel submitted that PB 1, PB 46 and 53 are copy of 8 notice u/s 153A dated 06.08.2013, copy of notice

Reena Khetan, Koderma vs. Income Tax Officer, Koderma

In the result, appeal of the assessee stands allowed

ITA 230/RAN/2023[2012-2013]Status: DisposedITAT Ranchi19 Aug 2025AY 2012-2013

Bench: S/ S/Hri George Mathan & Ratnesh Nandan Sahayratnesh Nandan Sahayratnesh Nandan Sahayassessment Year : 2012-13 Reena Khetan, M/S. Anand Reena Khetan, M/S. Anand Vs. Income Tax Officer, Ward - Income Tax Officer, Ward Vihar, Ranchi Patna Road, Vihar, Ranchi Patna Road, 1(5)Koderma Jhumritelaiya, Jhumritelaiya, Koderma, Koderma, Jharkhand Pan/Gir No. .Adlpk 5070 G (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Devesh Poddar, Adv Devesh Poddar, Adv Revenue By : Shri Khubchand T Pandya, Revenue By Ld Sr Dr Date Of Hearing : 20/08/202 2025 Date Of Pronouncement : 20/08/2 2025 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A), Cit(A), Nfac, Nfac, Delhi Delhi Dated Dated 28.8.2023 In In Appeal Appeal No.Cit(A) No.Cit(A) Hazaribag/10153/2019 Hazaribag/10153/2019-20 For The Assessment Year 2012-13 13. 2. Shri Devesh Poddar, Shri Devesh Poddar, Ld Ar Appeared For The Assessee. Shri Ed For The Assessee. Shri Khubchand T Pandya, Khubchand T Pandya, Ld Sr Dr Represented On Behalf Of The Revenue. Represented On Behalf Of The Revenue.

For Appellant: Shri Devesh Poddar, AdvFor Respondent: Shri Khubchand T Pandya

through banking channel. It was the submission that said Sakshi Vyapar Limited and another company namely M/s. Sharp Transport Pvt Ltd., were amalgamated into a company namely M/s. Oasis Cine Communication Ltd., (OCCL) vide order dated 11.6.2009 with the effective date of amalgamation on 1.4.2008. It was the submission that ... company OCCL has changed its name and now is M/s Ecowave Infotech Ltd (EIL). On the amalgamation, the assessee had received shares of OCCL in the ratio of 1:8. The assessee had sold shares during the impugned assessment year and derived capital gain of Rs.57

The Sankeshwar Souhard Credit Sahakari Limited, Sankeshwar vs. The Pr. Commissioner of Income Tax, Hubli

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

ITA 118/PAN/2025[2020-21]Status: DisposedITAT Panaji19 Aug 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.118/Pan/2025 (A.Y.2020-21 ) The Sankeshwar Souhard Vs. Pr.Cit, Credit Sahakari Ltd, C.R.Building, Cts.No.41443/B/234, Navanagar, Near Hanuman Temple, Hubli-580025, Nidasoshi Road, Karnataka Sankeshwar-591313, Karnataka. Pan .No.Aaaat8125C (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 143(3)Section 263Section 80PSection 80P(2)(d)

Assessing Officer to decide the aspect/question….” Similar view has been expressed by Hon’ble Madras High Court in the case of CIT Vs. Amalgamations Ltd (238 ITR 963). 9. Considering the ratio of decisions of the Honble High courts, it is clear the Pr.CIT before holding the order

Dy Commissioner of Income Tax Circle 7 Pune, Pune vs. Kumar Housing Corporation Private Limited, Pune

In the result, both the appeals filed by the assessee are allowed and the appeal filed by the Revenue is dismissed

ITA 341/PUN/2025[2013-14]Status: DisposedITAT Pune18 Aug 2025AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 32Section 36(1)(iii)

filing portal of the income tax department. Since in the present case the assessee had filed the letter informing the fact of amalgamation he held that the claim of the assessee is not acceptable. 7. So far as the decision of Hon’ble Supreme Court in the case of PCIT ... said decision is not applicable to the facts of the assessee. In that case the issuance of jurisdiction notice u/s 143(2) to the amalgamating company SPIL was undertaken on 26.09.2013 subsequent to the approval granted by the Hon’ble Delhi High Court for the Scheme of amalgamation

Kumar Urban Development Pvt. Ltd (Successor Kumar Housing Corpn. Pvt Ltd), Pune vs. DCIT Circle 14, Pune

In the result, both the appeals filed by the assessee are allowed and the appeal filed by the Revenue is dismissed

ITA 2875/PUN/2024[2013-14]Status: DisposedITAT Pune18 Aug 2025AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 32Section 36(1)(iii)

filing portal of the income tax department. Since in the present case the assessee had filed the letter informing the fact of amalgamation he held that the claim of the assessee is not acceptable. 7. So far as the decision of Hon’ble Supreme Court in the case of PCIT ... said decision is not applicable to the facts of the assessee. In that case the issuance of jurisdiction notice u/s 143(2) to the amalgamating company SPIL was undertaken on 26.09.2013 subsequent to the approval granted by the Hon’ble Delhi High Court for the Scheme of amalgamation

Kumar Urban Development Pvt. Ltd (Successor Kumar Housing Corporation Pvt Ltd), Pune vs. DCIT Circle 14, Pune

In the result, both the appeals filed by the assessee are allowed and the

ITA 2874/PUN/2024[2014-15]Status: DisposedITAT Pune18 Aug 2025AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 32Section 36(1)(iii)

filing portal of the income tax department. Since in the present case the assessee had filed the letter informing the fact of amalgamation he held that the claim of the assessee is not acceptable. 7. So far as the decision of Hon'ble Supreme Court in the case of PCIT ... said decision is not applicable to the facts of the assessee. In that case the issuance of jurisdiction notice u/s 143(2) to the amalgamating company SPIL was undertaken on 26.09.2013 subsequent to the approval granted by the Hon'ble Delhi High Court for the Scheme of amalgamation

Shri Basaveshwar Urban Co-Operative Credit Society Ltd, Mudalagi vs. The Principle Commissioner of Income Tax, Hubli

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

ITA 78/PAN/2025[2020-21]Status: DisposedITAT Panaji14 Aug 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.78/Pan/2025 (A.Y.2020-21) Shri Basaveshwar Urban Vs. Pr.Cit, Co_Op Credit Society C.R.Building, Mudalagi, Navanagar, Belagavi-591312, Hubli-580025, Karnataka Karnataka. Pan .No.Aaaas6800M (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Saidappa Gadadi.Ar Revenue By Shri.Captain Pradeep Arya.Cit.Dr सुनवाई की तारीख/Date Of Hearing 11.08.2025 घोषणा की तारीख/Date Of 14.08.2025 Pronouncement Order Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Pr. Commissioner Of Income Tax (Pr.Cit) Hubli Passed U/S 263 Of The Act. The Assesse Has Raised The Grounds Of Appeal Challenging The Revision Order Passed By The Pr.Cit Set Aside The Order Passed By The Assessing Officer. 2. The Brief Facts Of The Case Are That, The Assessee Is A Cooperative Credit Society & Has Filed The Return Of Income For The A.Y 2020-21 On 04.01.2021 Disclosing A Total Income Of

Section 142(1)Section 143(2)Section 143(3)Section 263Section 80PSection 80P(2)(d)

Assessing Officer to decide the aspect/question….” Similar view has been expressed by Hon’ble Madras High Court in the case of CIT Vs. Amalgamations Ltd (238 ITR 963). 10. Considering the ratio of decisions of the Honble Hight courts, it is clear the Pr.CIT before holding the order

DCIT, Circle-1(1)(1), Ahmedabad vs. Aia Engineering Limited, Ahmedabad

Appeal of the Revenue is dismissed

ITA 2170/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad14 Aug 2025AY 2021-22

Bench: Us. He Pointed Out That There Were Common Issues In All The Appeals Pertaining To The Following Additions:

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Shri Alpesh Parmar, CIT. DR
Section 250Section 80G

assessee treating it as plant and machinery. iii. Disallowance of claim of depreciation on goodwill, which goodwill was generated on account of amalgamation of M/s. DCPL Foundries Ltd. with the assessee in F.Y. 2013-14. iv. Disallowance of claim of deduction u/s.80G of the Act on account of Corporate Social ... depreciation on goodwill, Ld. Counsel pointed out that the said claim related to goodwill generated in the hands of the assessee on account of amalgamation of M/s. M/s. DCPL Foundries Ltd. with the assessee in F.Y. 2013-14. He pointed out that the ITAT had decided this issue in favour

DCIT, Circle-1(1)(1), Ahmedabad vs. Aia Engineering Limited, Ahmedabad

Appeal of the Revenue is dismissed

ITA 2169/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad14 Aug 2025AY 2020-21

Bench: Us. He Pointed Out That There Were Common Issues In All The Appeals Pertaining To The Following Additions:

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Shri Alpesh Parmar, CIT. DR
Section 250Section 80G

assessee treating it as plant and machinery. iii. Disallowance of claim of depreciation on goodwill, which goodwill was generated on account of amalgamation of M/s. DCPL Foundries Ltd. with the assessee in F.Y. 2013-14. iv. Disallowance of claim of deduction u/s.80G of the Act on account of Corporate Social ... depreciation on goodwill, Ld. Counsel pointed out that the said claim related to goodwill generated in the hands of the assessee on account of amalgamation of M/s. M/s. DCPL Foundries Ltd. with the assessee in F.Y. 2013-14. He pointed out that the ITAT had decided this issue in favour

DCIT, Circle - 1(1)(1), Ahmedabad vs. Aia Engineering Ltd, Ahmedabad

Appeal of the Revenue is dismissed

ITA 2168/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad14 Aug 2025AY 2018-19
For Appellant: Revenue byFor Respondent: Date of Hearing
Section 250Section 80G

assessee treating it as plant and machinery. iii. Disallowance of claim of depreciation on goodwill, which goodwill was generated on account of amalgamation of M/s. DCPL Foundries Ltd. with the assessee in F.Y. 2013-14. iv. Disallowance of claim of deduction u/s.80G of the Act on account of Corporate Social ... depreciation on goodwill, Ld. Counsel pointed out that the said claim related to goodwill generated in the hands of the assessee on account of amalgamation of M/s. M/s. DCPL Foundries Ltd. with the assessee in F.Y. 2013-14. He pointed out that the ITAT had decided this issue in favour

DCIT, Circle-1(1)(1), Ahmedabad vs. Aia Engineering Limited, Ahmedabad

Appeal of the Revenue is dismissed

ITA 2167/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad14 Aug 2025AY 2017-18

Bench: Us. He Pointed Out That There Were Common Issues In All The Appeals Pertaining To The Following Additions:

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Shri Alpesh Parmar, CIT. DR
Section 250Section 80G

assessee treating it as plant and machinery. iii. Disallowance of claim of depreciation on goodwill, which goodwill was generated on account of amalgamation of M/s. DCPL Foundries Ltd. with the assessee in F.Y. 2013-14. iv. Disallowance of claim of deduction u/s.80G of the Act on account of Corporate Social ... depreciation on goodwill, Ld. Counsel pointed out that the said claim related to goodwill generated in the hands of the assessee on account of amalgamation of M/s. M/s. DCPL Foundries Ltd. with the assessee in F.Y. 2013-14. He pointed out that the ITAT had decided this issue in favour

ACIT-2(1)(1), Mumbai vs. Bank of Baroda (E- Vijaya Bank), Mumbai

Appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 2583/MUM/2024[2018-19]Status: DisposedITAT Mumbai14 Aug 2025AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri S. Ananthan, ARFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR
Section 143(2)Section 143(3)Section 250Section 292B

return was revised on 30.03.2019 where the assessee declared a loss of Rs. 12,47,444/-. In the mean time in accordance with the "Amalgamation of Vijaya Bank and Dena Bank with Bank of Baroda Scheme 2019" the assessee i.e. Vijaya Bank along with Dena Bank got amalgamated with Bank ... that the notice under section 143(2) dated 23.09.2019 (page 1 of PB) was issued in the name of Vijaya Bank i.e. the amalgamated entity, post the amalgamation. The ld. AR also submitted that the assessee in response to the notices filed a reply dated 29.02.2020 wherein it is mentioned

Bank of Baroda (Erstwhile Vijaya Bank), Mumbai vs. Assistant Commissioner of Income Tax, Circle 2(1)(1), Mumbai

Appeal of the assessee is allowed and the appeal of the revenue is

ITA 2534/MUM/2024[2018-19]Status: DisposedITAT Mumbai14 Aug 2025AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

Section 143(2)Section 143(3)Section 250Section 292B

said return was revised on 30.03.2019 where the assessee declared a loss of Rs.12,47,444/-. In the mean time in accordance with the "Amalgamation of Vijaya Bank and Dena Bank with Bank of Baroda Scheme 2019" the assessee i.e. Vijaya Bank along with Dena Bank got amalgamated with Bank ... that the notice under section 143(2) dated 23.09.2019 (page 1 of PB) was issued in the name of Vijaya Bank i.e. the amalgamated entity, post the amalgamation. The ld. AR also submitted that the assessee in response to the notices filed a reply dated 29.02.2020 wherein it is mentioned

M/S T vs. Motor Company Limited, Chennaivs.ACIT Corporate Circle 3 (1), Chennai

ITA 2405/CHNY/2019[2014-14]Status: DisposedITAT Chennai13 Aug 2025AY 2014-14

Bench: Shri Aby T Varkey & Shri Amitabh Shukla

Section 92C(2)

April, 2018.] (2) If any new asset acquired and installed by the assessee is sold or otherwise transferred, except in connection with the amalgamation or demerger, within a period of five years from the date of its installation, the amount of deduction allowed under sub-section ... gains, arising on account of transfer of such new asset. (3) Where the new asset is sold or otherwise transferred in connection with the amalgamation or demerger within a period of five years from the date of its installation, the provisions of sub-section (2) shall apply to the amalgamated

ACIT-CC-7(3), Mumbai vs. Raniben Khimji Patel, Legal Heir of Shri Khimji Karamshi Patel, Mumbai

In the result, the grounds of appeal filed by the revenue are accordingly dismissedand order of Ld

ITA 1743/MUM/2025[2019-20]Status: DisposedITAT Mumbai13 Aug 2025AY 2019-20

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhanacit-Cc-7(3) Vs. Ranibenkhimji Patel R. No. 655, (Legal Heir Of Shri 6Thfloor,Aayakar Bhavan, Khimjikaramshi M. K. Road, Mumbai-400 Patel), 020 602, 6Th Floor, Petit Tower, August Kranti Marg, Kemps Corner, Mumbai-400 026 Pan/Gir No. Aadpp8816G (Applicant) (Respondent) Revenue By Shri Pravin Salunkhe, Sr. Dr Assessee By Shri Rushabh Mehta, Ld. Ar Date Of Hearing 03.07.2025 Date Of Pronouncement 13.08.2025 आदेश / Order Per Raj Kumar Chauhan, Jm:

Section 142(1)Section 143(3)Section 148Section 250Section 36(1)(iii)Section 69C

Shri KhimjiKaramshi Patel) PCIT v. Maruti Suzuki India Ltd. [2019] 107 taxmann.com 375 (SC), wherein the Apex Court was pleased to hold that the amalgamating entity ceases to exist upon the approved scheme of amalgamation and participation in the proceedings by the appellant in the circumstances cannot operate