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“slump exchange”

Mergers & RestructuringSection 2(42C)Section 2(42C)8 judgments

MAHADHAN AGRITECH LIMITED (FORMERLY KNOWN AS SMARTCHEM TECHNOLOGIES LTD),MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 8(1), MUMBAI

In the result, the appeals filed by the assessee are\nallowed, and the appeal filed by the Revenue is dismissed

ITA 5423/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Jul 2025AY 2020-21
Section 132Section 153A

assessee\ncompany. As per the scheme, the fertilizer and TAN\ndivisions owned by DFPCL were transferred to SCM by way\nof slump exchange. Further, the said divisions were\ndemerged from SCM to assessee company.\n(ii) The net value of assets transferred in demerger was Rs.\n743 crores. The sales ... purpose\nand methodology of valuation followed in both reports were\n49\nITA No.2227/Mum/2024 and others\nMahadhan Agritech Limited\ndifferent. Valuation for the purposes of slump exchange\nwas done at NAV method and valuation for the purposes of\ndemerger was done as per market as well as DCF Method

MAHADHAN AGRITECH LIMITED (FORMERLY KNOWN AS SMARTCHEM TECHNOLOGIES LIMITED ),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE -8(1), MUMBAI

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

ITA 3937/MUM/2024[2019-20]Status: DisposedITAT Mumbai24 Jul 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

assessee company. As per the scheme, the fertilizer and TAN divisions owned by DFPCL were transferred to SCM by way of slump exchange. Further, the said divisions were demerged from SCM to assessee company. (ii) The net value of assets transferred in demerger was Rs. 743 crores. The sales consideration ... purpose of proposed demerger. The purpose and methodology of valuation followed in both reports were different. Valuation for the purposes of slump exchange was done at NAV method and valuation for the purposes of demerger was done as per market as well as DCF Method. 57. In determining the equity

DCIT CENTRAL CIRCLE 8(1), MUMBAI vs. MAHADHAN AGRITECH LIMITED, PUNE

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

ITA 3569/MUM/2024[2019-20]Status: DisposedITAT Mumbai24 Jul 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

assessee company. As per the scheme, the fertilizer and TAN divisions owned by DFPCL were transferred to SCM by way of slump exchange. Further, the said divisions were demerged from SCM to assessee company. (ii) The net value of assets transferred in demerger was Rs. 743 crores. The sales consideration ... purpose of proposed demerger. The purpose and methodology of valuation followed in both reports were different. Valuation for the purposes of slump exchange was done at NAV method and valuation for the purposes of demerger was done as per market as well as DCF Method. 57. In determining the equity

MAHADHAN AGRITECH LIMITED (FORMERLY KNOWN AS SMARTCHEM TECHNOLOGIES LTD ,MUMBAI vs. COMMISSIONER OF INCOME TAX(APPEAL)--50, MUMAI

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

ITA 2229/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Jul 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

assessee company. As per the scheme, the fertilizer and TAN divisions owned by DFPCL were transferred to SCM by way of slump exchange. Further, the said divisions were demerged from SCM to assessee company. (ii) The net value of assets transferred in demerger was Rs. 743 crores. The sales consideration ... purpose of proposed demerger. The purpose and methodology of valuation followed in both reports were different. Valuation for the purposes of slump exchange was done at NAV method and valuation for the purposes of demerger was done as per market as well as DCF Method. 57. In determining the equity

MAHADHAN AGRITECH LIMITED (FORMERLY KNWON AS SMARTECH TECHNOLOGIES LTD ) ,MUMBAI vs. COMMISSIONER OF INCOME TAX (APPEALS)-MUMBAI-50, MUMBAI

In the result, the appeals filed by the assessee are\nallowed, and the appeal filed by the Revenue is dismissed

ITA 2228/MUM/2024[2016-17]Status: DisposedITAT Mumbai24 Jul 2025AY 2016-17
Section 132Section 153A

assessee\ncompany. As per the scheme, the fertilizer and TAN\ndivisions owned by DFPCL were transferred to SCM by way\nof slump exchange. Further, the said divisions were\ndemerged from SCM to assessee company.\n(ii) The net value of assets transferred in demerger was Rs.\n743 crores. The sales ... nand methodology of valuation followed in both reports were\n\nITA No.2227/Mum/2024 and others\nMahadhan Agritech Limited\n50\ndifferent. Valuation for the purposes of slump exchange\nwas done at NAV method and valuation for the purposes of\ndemerger was done as per market as well as DCF Method

MAHADHAN AGRITECH LIMITED (FORMERLY KNOWN AS SMARTECH TECHNOLOGIES LTD ,MUMBAI vs. COMMISSIONER OF INCOME TAX (APPEALS)-MUMBAI.50, MUMBAI

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

ITA 2227/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Jul 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

assessee company. As per the scheme, the fertilizer and TAN divisions owned by DFPCL were transferred to SCM by way of slump exchange. Further, the said divisions were demerged from SCM to assessee company. (ii) The net value of assets transferred in demerger was Rs. 743 crores. The sales consideration ... purpose of proposed demerger. The purpose and methodology of valuation followed in both reports were different. Valuation for the purposes of slump exchange was done at NAV method and valuation for the purposes of demerger was done as per market as well as DCF Method. 57. In determining the equity

ISC SPECIALITY CHEMICALS LLP ,MUMBAI vs. ITO WARD 19(1)(5), MUMBAI

In the result the appeal filed by the assessee stands partly allowed

ITA 457/MUM/2025[2018-19]Status: DisposedITAT Mumbai28 May 2025AY 2018-19

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 45Section 47Section 47A(4)Section 48Section 50BSection 56

above, the conversion of private limited company into LLP in lieu of interest in the LLP given to the shareholders is case of "slump exchange" and therefore, not chargeable to tax. 8. Without prejudice to the above, section 50B ought to have been invoked and since the undertaking has been

SATISH BACHUBHAI AMLANI,FORT-MUMBAI vs. ASSTT. COMMISSIONER OF INCOME TAX-17(3), BANDRA-MUMBAI

In the result, the appeal by the assessee is allowed

ITA 4442/MUM/2024[2013-14]Status: DisposedITAT Mumbai21 Oct 2024AY 2013-14

Bench: Shri Amarjit Singhshri Sandeep Singh Karhailsatish Bachubhai Amlani 7301 Elphinstone House, 17 Murzban Road, Fort, Mumbai, Maharashtra–400001 ……………. Appellant Pan: Aabpa4047J

For Appellant: Shri Jisgnesh ParikhFor Respondent: Shri BhangepatilPushkaraj Ramesh, Sr.DR
Section 142(1)Section 143(2)Section 143(3)Section 250Section 271Section 271(1)(c)Section 47Section 50B

amounting to Rs. 9,83,137. Accordingly, the assessee was asked to show cause as to why the transaction should not be considered a slump exchange instead of a slump sale. The assessee was also asked to show cause as to why the transaction should not be considered ... books of M/s Satish Enterprise Private Limited. Accordingly, the AO held that the transaction carried out by the assessee should be considered a slump exchange in opposition to a slump sale and the loss claimed by the assessee cannot be allowed. In further appeal, the learned CIT(A) upheld