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“scheme of arrangement”

Mergers & RestructuringSection 391-394Section 391-394328 judgments

The decision most relied on for scheme of arrangement is Spice Infotainment Ltd. v. CIT (247 CTR 500), cited in 114 judgments on BharatTax.

Leading authorities on scheme of arrangement

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.

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. Intel Technology India (P.) Ltd.
380 ITR 272 · 2016 · High Court
45
citing judgments

When an amalgamating company ceases to exist due to a scheme of arrangement or merger, any subsequent assessment or action under the Income-tax Act initiated against that non-existent entity is void ab initio, as it is not a 'person' under Section 2(31).

CIT v. Smifs Securities Ltd.
87 Taxmann.com 82 · 2017 · High Court
38
citing judgments

Depreciation is allowable on goodwill as an intangible asset under Section 32(1)(ii) when it arises from a scheme of amalgamation or similar corporate restructuring.

Rustagi Engineering Udyog (P.) Ltd. v. Deputy Commissioner of Income-tax
382 ITR 443 · 2016 · High Court
25
citing judgments

An amalgamation that has been brought to the notice of the Assessing Officer is void ab initio, meaning it is invalid from the beginning.

DCIT v. Toyo Engineering India ltd.
33 Taxmann.com 560 · 2013 · Reported
22
citing judgments

Depreciation is not allowed on goodwill if it arises from book entries and has no identifiable cost of acquisition. This applies even when goodwill is acquired as part of a scheme of arrangement or amalgamation.

Dalmia Power Ltd. v. ACIT
420 ITR 339 · 2020 · Supreme Court
21
citing judgments

Once a scheme of arrangement or amalgamation has been sanctioned by a competent court and due notice has been issued to the income tax department, the binding nature of the scheme cannot be challenged during its implementation, as it attains statutory force.

Killick Nixon Ltd. v. Deputy Commissioner of Income-tax
20 Taxmann.com 703 · 2012 · High Court
20
citing judgments

Transactions lacking commercial substance, such as circular share transactions designed to generate artificial capital losses, are not genuine and may be disregarded by tax authorities.

Judgments citing scheme of arrangement

Shriram Finance Ltd., Chennai vs. PCIT, Chennai

ITA 2043/CHNY/2025[2022-23]Status: DisposedITAT Chennai08 Jan 2026AY 2022-23

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2043/Chny/2025 िनधा"रण वष"/Assessment Year: 2022-23 Shriram Finance Limited, Vs. The Principal Commissioner Of [Since Shriram City Union Finance Income Tax – 3, Limited Amalgamated With Shriram Chennai. Transport Finance Co. Limited & Presently Known As Shriram Finance Limited], Sri Towers, Plot No. 14A, South Phase, Industrial Estate, Guindy, Chennai 600 032. [Pan:Aaacs7018R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 15.10.2025 घोषणा की तारीख /Date Of Pronouncement : 08.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.05.2025 Passed By The Ld. Principal Commissioner Of Income Tax – 3, Chennai For The Assessment Year 2022-23 Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri C.N. Bipin, CIT
Section 143(3)Section 234DSection 263Section 36(1)(vii)Section 36(1)(viia)Section 4

submission of assessee to the Income Tax Department is as follows: "We wish to bring to your kind attention that pursuant to composite Scheme of Arrangements (Amalgamation and Demerger) sanctioned by NCLT 6 I.T.A. No.2043/Chny/25 Chennai vide order dated 09/11/2022 [for which the assessing officer of the then amalgamating company ... recovery of any tax statutorily due from transferor or transferee company or any other person liable to pay such tax due, the scheme of arrangement as approved by NCLT was not be interfered with." 6. The ld. DR submits that the case laws as cited by the assessee Kamala Muthaiah