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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

ACIT Company Circle II(3), Chennai vs. Indian Bank Ltd., Chennai

In the result, appeals filed by the Revenue in all assessment years

ITA 882/CHNY/2006[1999-2000]Status: DisposedITAT Chennai21 Dec 2022AY 1999-2000

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Mr. Sanjeev Aditiya, FCAFor Respondent: Mr.R.Mohan Reddy, CIT
Section 43(1)

that in all these assessment years, the assessee has claimed depreciation on assets taken over from Bank of Thanjavur Ltd., in pursuant to amalgamation of Bank of Thanjavur Ltd., with assessee’s bank approved by Reserve Bank of India. The assessee’s bank has claimed depreciation on assets taken over ... from Bank of Thanjavur Ltd., on the basis of value fixed in pursuant to arrangement between the assessee’s bank and amalgamated bank on the ground that the value of assets has been determined by the Government of India for the purpose of taking over the banking business

ACIT, Chennai vs. Indian Bank Ltd, Chennai

In the result, appeals filed by the Revenue in all assessment years

ITA 2369/CHNY/2004[1996-1997]Status: DisposedITAT Chennai21 Dec 2022AY 1996-1997

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Mr. Sanjeev Aditiya, FCAFor Respondent: Mr.R.Mohan Reddy, CIT
Section 43(1)

that in all these assessment years, the assessee has claimed depreciation on assets taken over from Bank of Thanjavur Ltd., in pursuant to amalgamation of Bank of Thanjavur Ltd., with assessee’s bank approved by Reserve Bank of India. The assessee’s bank has claimed depreciation on assets taken over ... from Bank of Thanjavur Ltd., on the basis of value fixed in pursuant to arrangement between the assessee’s bank and amalgamated bank on the ground that the value of assets has been determined by the Government of India for the purpose of taking over the banking business

ACIT Company Circle II(3), Chennai vs. Indian Bank Ltd., Chennai

In the result, appeals filed by the Revenue in all assessment years

ITA 2368/CHNY/2004[1995-96]Status: DisposedITAT Chennai21 Dec 2022AY 1995-96

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Mr. Sanjeev Aditiya, FCAFor Respondent: Mr.R.Mohan Reddy, CIT
Section 43(1)

that in all these assessment years, the assessee has claimed depreciation on assets taken over from Bank of Thanjavur Ltd., in pursuant to amalgamation of Bank of Thanjavur Ltd., with assessee’s bank approved by Reserve Bank of India. The assessee’s bank has claimed depreciation on assets taken over ... from Bank of Thanjavur Ltd., on the basis of value fixed in pursuant to arrangement between the assessee’s bank and amalgamated bank on the ground that the value of assets has been determined by the Government of India for the purpose of taking over the banking business

ACIT Company Circle II(3), Chennai vs. Indian Bank Ltd., Chennai

In the result, appeals filed by the Revenue in all assessment years

ITA 2366/CHNY/2004[1993-1994]Status: DisposedITAT Chennai21 Dec 2022AY 1993-1994

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Mr. Sanjeev Aditiya, FCAFor Respondent: Mr.R.Mohan Reddy, CIT
Section 43(1)

that in all these assessment years, the assessee has claimed depreciation on assets taken over from Bank of Thanjavur Ltd., in pursuant to amalgamation of Bank of Thanjavur Ltd., with assessee’s bank approved by Reserve Bank of India. The assessee’s bank has claimed depreciation on assets taken over ... from Bank of Thanjavur Ltd., on the basis of value fixed in pursuant to arrangement between the assessee’s bank and amalgamated bank on the ground that the value of assets has been determined by the Government of India for the purpose of taking over the banking business

DCIT, Chennai vs. M/S. Indian Bank, Chennai

In the result, appeals filed by the Revenue in all assessment years

ITA 983/CHNY/2003[1994-1995]Status: DisposedITAT Chennai21 Dec 2022AY 1994-1995

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Mr. Sanjeev Aditiya, FCAFor Respondent: Mr.R.Mohan Reddy, CIT
Section 43(1)

that in all these assessment years, the assessee has claimed depreciation on assets taken over from Bank of Thanjavur Ltd., in pursuant to amalgamation of Bank of Thanjavur Ltd., with assessee’s bank approved by Reserve Bank of India. The assessee’s bank has claimed depreciation on assets taken over ... from Bank of Thanjavur Ltd., on the basis of value fixed in pursuant to arrangement between the assessee’s bank and amalgamated bank on the ground that the value of assets has been determined by the Government of India for the purpose of taking over the banking business

DCIT, Chennai vs. M/S. Indian Bank, Chennai

In the result, appeals filed by the Revenue in all assessment years

ITA 1227/CHNY/2003[1998-1999]Status: DisposedITAT Chennai21 Dec 2022AY 1998-1999

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Mr. Sanjeev Aditiya, FCAFor Respondent: Mr.R.Mohan Reddy, CIT
Section 43(1)

that in all these assessment years, the assessee has claimed depreciation on assets taken over from Bank of Thanjavur Ltd., in pursuant to amalgamation of Bank of Thanjavur Ltd., with assessee’s bank approved by Reserve Bank of India. The assessee’s bank has claimed depreciation on assets taken over ... from Bank of Thanjavur Ltd., on the basis of value fixed in pursuant to arrangement between the assessee’s bank and amalgamated bank on the ground that the value of assets has been determined by the Government of India for the purpose of taking over the banking business

DCIT, Chennai vs. M/S. Indian Bank, Chennai

In the result, appeals filed by the Revenue in all assessment years

ITA 1226/CHNY/2003[1997-1998]Status: DisposedITAT Chennai21 Dec 2022AY 1997-1998

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Mr. Sanjeev Aditiya, FCAFor Respondent: Mr.R.Mohan Reddy, CIT
Section 43(1)

that in all these assessment years, the assessee has claimed depreciation on assets taken over from Bank of Thanjavur Ltd., in pursuant to amalgamation of Bank of Thanjavur Ltd., with assessee’s bank approved by Reserve Bank of India. The assessee’s bank has claimed depreciation on assets taken over ... from Bank of Thanjavur Ltd., on the basis of value fixed in pursuant to arrangement between the assessee’s bank and amalgamated bank on the ground that the value of assets has been determined by the Government of India for the purpose of taking over the banking business

DCIT, Chennai vs. M/S. Indian Bank, Chennai

In the result, appeals filed by the Revenue in all assessment years

ITA 1225/CHNY/2003[1992-1993]Status: DisposedITAT Chennai21 Dec 2022AY 1992-1993

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Mr. Sanjeev Aditiya, FCAFor Respondent: Mr.R.Mohan Reddy, CIT
Section 43(1)

that in all these assessment years, the assessee has claimed depreciation on assets taken over from Bank of Thanjavur Ltd., in pursuant to amalgamation of Bank of Thanjavur Ltd., with assessee’s bank approved by Reserve Bank of India. The assessee’s bank has claimed depreciation on assets taken over ... from Bank of Thanjavur Ltd., on the basis of value fixed in pursuant to arrangement between the assessee’s bank and amalgamated bank on the ground that the value of assets has been determined by the Government of India for the purpose of taking over the banking business

DCIT, Chennai vs. M/S. Indian Bank, Chennai

In the result, appeals filed by the Revenue in all assessment years

ITA 1224/CHNY/2003[1991-1992]Status: DisposedITAT Chennai21 Dec 2022AY 1991-1992

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Mr. Sanjeev Aditiya, FCAFor Respondent: Mr.R.Mohan Reddy, CIT
Section 43(1)

that in all these assessment years, the assessee has claimed depreciation on assets taken over from Bank of Thanjavur Ltd., in pursuant to amalgamation of Bank of Thanjavur Ltd., with assessee’s bank approved by Reserve Bank of India. The assessee’s bank has claimed depreciation on assets taken over ... from Bank of Thanjavur Ltd., on the basis of value fixed in pursuant to arrangement between the assessee’s bank and amalgamated bank on the ground that the value of assets has been determined by the Government of India for the purpose of taking over the banking business

Xchanging Solutions Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, the appeal is partly allowed

ITA 292/BANG/2022[2017-18]Status: DisposedITAT Bangalore21 Dec 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri K. Sankar Ganesh, Jt.CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)

that this asset is appearing in the books of the company because of adoption of pooling of interest method to give effect to the amalgamation. The assessee had not paid IT(TP)A No.292/Bang/2022 Page 32 of 42 any consideration to acquire this asset as the same was not expected

Vulvan Traders Private Limited, Mumbai vs. Principle Commissioner of Income Tex, Mumbai-5, Mumbai

The appeal of the assessee is allowed

ITA 1318/MUM/2022[2012-2013]Status: DisposedITAT Mumbai19 Dec 2022AY 2012-2013

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Principle Commissioner Of Vulvan Traders Private Income Tax, Limited 515, 5Th Floor, 805A, Corporate Avenue, Aaykar Bhavan, Sonawala Road, Vs. Goregaon (East) Mk Road, Mumbai-400 063 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaacv1603K Assessee By : Shri Rajeev Khandelwal, Ar Revenue By : Shri Achal Sharma, Cit Dr Date Of Hearing: 21.09.2022 Date Of Pronouncement : 19.12.2022

For Appellant: Shri Rajeev Khandelwal, ARFor Respondent: Shri Achal Sharma, CIT DR
Section 143(3)Section 147Section 148Section 263

Sanchayita Tradelink Pvt. Ltd merged with the assessee company with effect from 1April 2011 on Vulvan Traders Private Limited.; A.Y. 2012-13 amalgamation approved by the Hon'ble Bombay High Court vide order dated 29June 2012. The learned Assessing Officer obtained relevant documents, examined the same and placed it record ... breakup of credit entries received in the bank account of Morsel Traders Pvt. Ltd. Were explained. iii. Ld. AO was also shown notes of Amalgamation pursuant to the order of the Honourable High court. iv. Ld. AO was submitted reconciliation of form no.26AS of the amount credited

Konecranes P.Ltd, Pune vs. Asst CIT Cir 3(2)(2), Mumbai

In the result, appeal by the assessee is allowed

ITA 1497/MUM/2017[2012-13]Status: DisposedITAT Mumbai15 Dec 2022AY 2012-13

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं. 1497/मुं/ 2017 ("न.व. 2012-13) Konecranes Private Limited Pan:Aaacw0328C(Pan Of Merged Entity) Pan Of Old Entity Aacck9930E Being Konecranes India Private Limited) 19, Level -2, Muttha Towers, Don Bosco Road,Yerwada, Dist. Pune – 411 006. ...... अपीलाथ" /Appellant बनाम Vs. Assistant Commissioner Of Income-Tax, Circle 3(2)(2), Mumbai. Room No.608, 6Th Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri Dhanesh Bafna With S/Shri Amol Mahajan & Hardik Nirmal ""तवाद" "वारा/Respondent By : Ms. Samrudhi Dhananjay Hande सुनवाई क" "त"थ/ Date Of Hearing : 15/12/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 15/12/2022 आदेश/ Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 31/01/2017 Passed U/S. 143(3) R.W.S. 144C(13) R.W.S. 92Ca(3) Of The Income Tax Act, 1961 [ In Short ‘The Act’], For The Assessment Year 2012-13. 2 2. The Assessee Has Filed Additional Ground Of Appeal Vide Application Dated 29/08/2019 Assailing The Validity Of Assessment Order Passed In The Name Of A Non-Existing Entity. The Additional Ground Raised By The Assessee Reads As Under:

For Appellant: Shri Dhanesh Bafna with S/Shri Amol Mahajan & Hardik NirmalFor Respondent: Ms. Samrudhi Dhananjay Hande
Section 143(3)Section 144C(5)Section 92C

Konecranes India Private Limited', an entity which is not in existence on the date of passing the impugned orders on account of its amalgamation with the Appellant. It is the humble prayer of the Appellant that the draft assessment order and final assessment order passed by Ld. AO be held ... appeal would become academic. 2.1 Narrating sequence of events the ld. Authorized Representative for the assessee submits, that consequent to approval of scheme of amalgamation approved by Hon'ble Bombay High Court vide order dated 02/11/2012 w.e.f. 01/04/2012 Konecranes India Pvt. Ltd. was amalgamated with WMI Konecranes India

Symantec Software Solutions P.Ltd, Mumbai vs. DCIT Cir 14(3)(2), Mumbai

In the result, the appeals filed by the assessee are partly allowed

ITA 565/MUM/2016[2011-12]Status: DisposedITAT Mumbai13 Dec 2022AY 2011-12

Bench: Shri Prashant Maharishi, Accountat Member & Shri Pavan Kumar Gadale & M/S Symantec Software Vs. Dcit, Circle – 14(3)(2) Solutions Pvt Ltd Mumbai. Unit No. 1801, 18Th Floor The Capital, Plot No. 70, G Block, Bkc, Mumbai – 400051. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabcv2624B Appellant .. Respondent Appellant By : Shri.Nikhil Tiwari.Ar Respondent By : Shri.Rignesh Das.Dr Date Of Hearing 17.10.2022 Date Of Pronouncement 29.11.2022 आदेश / O R D E R Per Pavan Kumar Gadale, Jm: The Hon’Ble Tribunal Has Passed Ma No. 73 & 74/Mum/2021 In The Common Order Of Ita Nos. 565/Mum/2016 & 1906/Mum/2017 Dated 15.09.2017. The Ld. Ar Submitted That The Hon’Ble Tribunal In The Ma Has Considered The Assessee’S

For Appellant: Shri.Nikhil Tiwari.ARFor Respondent: Shri.Rignesh Das.DR

item referred ITA No. 565/Mum/2016 & 1906/Mum/2017 M/s. Symantec Software Solutions Pvt Ltd., Mumbai. to page 991 of the paper book that there is an amalgamation of persistent systems and there is a extraordinary general meeting event. We considering the facts and there is an extraordinary general meeting and the amalgamation

Wissen Infotech Private Limited, Hyderabad vs. Deputy Commisssioner of Income Tax, Circle-17(2), Hyderabad

In the result, the appeal of assessee in ITA

ITA 329/HYD/2021[2016-17]Status: DisposedITAT Hyderabad12 Dec 2022AY 2016-17

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri P.V.S.S.Prasad, CAFor Respondent: Shri Jeevan Lavidiya, CIT-DR
Section 234ASection 92C

dissimilar- Banking services, financial services, Media, entertainment, Hi-Tech and consumer electronics • Presence of intangibles – IPR • Presence of Brand • Incurred marketing expenses • Extraordinary events: Amalgamation of L & T Infotech Ltd. with ISRC, GDA Technologies Limited. Judicial pronouncements relied on: • ADP (P.) Ltd. v. Deputy Commissioner of Income-tax, Hyderabad

Wissen Infotech Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-17(2), Hyderabad

In the result, the appeal of assessee in ITA

ITA 1820/HYD/2019[2015-16]Status: DisposedITAT Hyderabad12 Dec 2022AY 2015-16

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri P.V.S.S.Prasad, CAFor Respondent: Shri Jeevan Lavidiya, CIT-DR
Section 234ASection 92C

dissimilar- Banking services, financial services, Media, entertainment, Hi-Tech and consumer electronics • Presence of intangibles – IPR • Presence of Brand • Incurred marketing expenses • Extraordinary events: Amalgamation of L & T Infotech Ltd. with ISRC, GDA Technologies Limited. Judicial pronouncements relied on: • ADP (P.) Ltd. v. Deputy Commissioner of Income-tax, Hyderabad

M/S Jsw Steel Ltd., Mumbai vs. Asst CIT CC 3 (2), Mumbai

ITA 349/MUM/2020[2012-13]Status: DisposedITAT Mumbai12 Dec 2022AY 2012-13
For Appellant: Shri Rakesh JoshiFor Respondent: Shri Achal Sharma
Section 143(3)Section 37(1)

INCOME TAX APPELLATE TRIBUNAL "F" BENCH, MUMBAI SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER M/s JSW Steel Limited. (Successor on amalgamation with M/s JSW Ispat Steel Ltd.) [PAN: AAACI6293E] …………… Appellant Vs Assistant Commissioner of Income Tax, Central Circle – 3(2), Mumbai, JSW Centre, BKC Bandra (East), ……………. Respondent ... DCIT, Central Circle –8(3), Room No. 656, 6th Floor, Aayakar Bhavan, M.K. Road, Mumbai - 400020 ……………… Appellant M/s JSW Steel Limited. Vs (Successor on amalgamation with M/s JSW Ispat Steel Ltd.) [PAN: AAACI6293E] ……………. Respondent Appearances For the Appellant/Assessee : Shri Rakesh Joshi For the Respondent/Department : Shri Achal Sharma Date of conclusion

Siemens Ltd, Mumbai vs. DCIT 8(2)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 1954/MUM/2016[2011-12]Status: DisposedITAT Mumbai12 Dec 2022AY 2011-12

Bench: Shri M. Balaganesh & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Ms. Vatsalaa Jha
Section 143(3)Section 144C(13)Section 92C(3)

Kolkata. Pursuant to the order dated 17/08/2012, passed by the Hon’ble Bombay High Court, Siemens VAI Metals Technologies Pvt. Ltd, inter-alia, was amalgamated with Siemens Ltd. with effect from 01/10/2011. As a consequence, Siemens Ltd was the resultant amalgamated company, and Siemens VAI Metals Technologies ... erstwhile company, ceased to exist subsequent to the approval of the scheme of amalgamation by the Hon’ble Bombay High Court. The assessee vide letter dated 18/10/2012, intimated the DCIT, Kolkata about the aforesaid amalgamation. Thereafter, vide another letter dated 06/05/2013, the assessee again intimated the DCIT, Kolkata about

M/S. J.P. Morgan India Pvt. Ltd, Mumbaiq vs. The Addl CIT Spl RG. 22, Mumbai

ITA 2406/MUM/2002[1998-99]Status: DisposedITAT Mumbai05 Dec 2022AY 1998-99
For Appellant: Shri Madhur AgarwalFor Respondent: Shri Santhil Kumaran
Section 143(3)

India Securities Pvt. Ltd. (name changed to J.P. Morgan India Private Limited) being successor to Jardinee Fleming India Broking Limited pursuant to scheme of amalgamation approved by Hon‟ble Bombay High Court, vide order dated 03.04.2000. 3. The Appellant has raised additional ground which read as under: “The Appellant submits ... order was framed by the Assessing Officer on March 16, 2001 on Jardinee Fleming India Broking Ltd. which ceased to exist pursuant to its amalgamation into Jardinee Fleming India Securities Pvt. Ltd. with effect from April 01, 1999, the assessment in so far as it is framed

Deputy Commissioner of Income Tax, Circle-1(1), Hubballi vs. M/S. Karnataka Vikas Grameen Bank Limited, Dharwad

In the result, the appeal of assessee is partly allowed and the appeal of the revenue is dismissed

ITA 720/BANG/2020[2016-17]Status: DisposedITAT Bangalore05 Dec 2022AY 2016-17

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2016-17

For Appellant: Shri S Ananthan, C.AFor Respondent: Ms. Susan D George, CIT (DR)
Section 143Section 234BSection 250Section 36

single Regional Rural Bank, i.e., the appellant M/s Karnataka Vikas Grameena Bank, Belgaum Road, Dharwad - 580 008. a) The appellant came into being by amalgamation of the four Regional Rural Banks, on the date of the publication in the Official Gazette, i.e., on 12/09/2005 and was to operate ... para no. 2 of the assessment order itself has recorded a finding that the respondent-assessee came into existence w.e.f. 31-3-2008, after amalgamation of the two Regional Rural Banks (RRB) i.e. Baroda Eastern U.P. Gramin Bank and Baroda Western Gramin Bank. It has not been disputed that

M/S Karnataka Vikas Grameena Bank, Dharwad vs. Assistant Commissioner of Income Tax, Circle-2(1), Hubballi

In the result, the appeal of assessee is partly allowed and the appeal of the revenue is dismissed

ITA 611/BANG/2020[2016-17]Status: DisposedITAT Bangalore02 Dec 2022AY 2016-17

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2016-17

For Appellant: Shri S Ananthan, C.A, S.V Ravishankar, AdvocateFor Respondent: Ms. Susan D George, CIT (DR)
Section 143Section 234BSection 250Section 36

single Regional Rural Bank, i.e., the appellant M/s Karnataka Vikas Grameena Bank, Belgaum Road, Dharwad - 580 008. a) The appellant came into being by amalgamation of the four Regional Rural Banks, on the date of the publication in the Official Gazette, i.e., on 12/09/2005 and was to operate ... para no. 2 of the assessment order itself has recorded a finding that the respondent-assessee came into existence w.e.f. 31-3-2008, after amalgamation of the two Regional Rural Banks (RRB) i.e. Baroda Eastern U.P. Gramin Bank and Baroda Western Gramin Bank. It has not been disputed that