“resulting company”

Mergers & RestructuringSection 2(41A)Section 2(41A)236 judgments

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

section 170 or to the amalgamating company and the amalgamated company in the case of amalgamation, or to the demerged company and the resulting company in the case of demerger, as the case may be, shall not exceed in any previous year the deduction calculated at the prescribed rates ... deduction shall be apportioned between the predecessor and the successor, or the amalgamating company and the amalgamated company, or the demerged company and the resulting company, as the case may be, in the ratio of the number of days for which the assets were used by them.” Page

ACIT, CIRCLE-7(1), DELHI, DELHI vs. DELHI CONTROL DEVICES PRIVATE LIMITED, DELHI

In the result, the revenue’s appeal is dismissed

ITA 5909/DEL/2025[2018-19]Status: HeardITAT Delhi05 Mar 2026AY 2018-19

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahmanasstt. Year : 2018-19

For Appellant: NoneFor Respondent: Shri Manish Gupta, Sr. DR

Section 14Section 147Section 53

Statecon Electronics India Ltd. and as per the para 9 of the NCLT order, no demand or proceedings can be made against the resulting company. With its submission, the appellant has attached the copy of NCLT order and also reproduced Clause-9 of the said order in its submission

ACIT, NEW DELHI vs. SH. ATUL BANSAL, NEW DELHI

In the result, grounds raised by the revenue are dismissed

ITA 2803/DEL/2017[2013-14]Status: DisposedITAT Delhi06 Feb 2026AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanatul Bansal, Vs. Acit, Central Circle 16 Farm No. 22, The Green Rajokri Delhi. New Delhi – 110 038. (Pan: Agcpb1274F) Acit, Central Circle 16, Vs, Atul Bansal Delhi Farm No. 22, The Green Rajokri New Delhi – 110 038. (Pan: Agcpb1274F) Assessee By : None Revenue By : Sh. Jitender Singh, Cit Dr Date Of Hearing : 18.11.2025 Date Of Order : 06.02.2026 O R D E R

For Appellant: NoneFor Respondent: Sh. Jitender Singh, CIT DR

Section 143(1)Section 143(2)Section 14ASection 2(22)(e)Section 54Section 54B

accordance with the provisions of section 77A of the Companies Act, 1956); (v) any distribution of shares pursuant to a demerger by the resulting company to the shareholders of the demerged company (whether or not there is a reduction of capital in the demerged company).] Explanation 1- The expression "accumulated

SH. ATUL BANSAL,NEW DELHI vs. ACIT, NEW DELHI

In the result, grounds raised by the revenue are dismissed

ITA 2737/DEL/2017[2013-14]Status: DisposedITAT Delhi06 Feb 2026AY 2013-14

For Appellant: NoneFor Respondent: Sh. Jitender Singh, CIT DR

Section 143(1)Section 143(2)Section 14ASection 2(22)(e)Section 54Section 54B

ANANG KUNJVIHARIBHAI SHAH,AHMEDABAD vs. THE ITO, WARD-7(2)(1) (PREVIOUSLY DCIT, CIRCLE-1(1)(2)), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 1156/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad03 Feb 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalincome-Tax Officer, Anang Kunjviharibhai Shah, Vs. Ward 7(2)(1), 1, Friends Colony, Sm Road, Vejalpur, Ahmedabad Ambawadi, Ahmedabad-380015 [Pan: Acups 2559 J] (Previously Dcit, Cir. 1(1)(2)) (Appellant) .. (Respondent) Appellant By: Shri Bandish Soparkar, Ar Respondent By: Shri Abhijit, Sr. Dr Date Of Hearing 27.11.2025 Date Of Pronouncement 03.02.2026

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Abhijit, Sr. DR

Section 2(22)(e)Section 250Section 80G

provisions of section 77A of the Companies Act, 1956 (1 of 1956); (v) any distribution of shares pursuant to a demerger by the resulting company to the shareholders of the demerged company (whether or not there is a reduction of capital in the demerged company).” Since the company

HARSHAD HIMMATLAL RUPANI,PUNE vs. ITO WARD 5(2), PUNE

In the result the ground number 3 is allowed for Statistical

ITA 920/PUN/2025[2014-15]Status: DisposedITAT Pune28 Jan 2026AY 2014-15

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.920/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15 Harshad Himmatlal Rupani, V The Income Tax Officer, 101/102, Ashoka Building, S Ward-5(1), Pune. Green Valley Housing Society, Wanwadi, Pune – 411040. Pan: Adopr6163Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Mahavir Jain Revenue By Smt Neha Thakur – (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 28/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2014-15 Dated 26.08.2024 Emanating From The Assessment Order Passed Under Section 143(3) Of The Income Tax Act, 1961, Dated 22.11.2016. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 250Section 41(1)

firm carrying on a business or profession is succeeded by another firm, the other firm; (iv) where there has been a demerger, the resulting company. ITA No.920/PUN/2025 [A] 6.3.1) Section 41(1) is for cessation of liability. In this case the Assessee has submitted Ledger Accounts duly signed

ACID, CIRCLE-5(1), KOLKATA, KOLKATA vs. EMAMI REALTY LIMITED, KOLKATA

In the result, both the appeal of the Revenue and cross objections of the assessee are\ndismissed

ITA 1457/KOL/2024[2021-22]Status: DisposedITAT Kolkata12 Jan 2026AY 2021-22

Section 143(3)Section 194ISection 2Section 250Section 50CSection 56Section 56(2)Section 56(2)(x)

liabilities pertaining to the real estate segment was reported to be\nRs.20.28 crores. The AO further held that, Section 2(19AA)(iv) required the resulting company\nto allot shares in a proportionate manner and because the assessee did not follow Rule 11UA\nof the IT Rules, 1962 to value ... firstly agree with the argument of the Id counsel for the assessee\nthat, Section 2(19AA)(iv) only stipulates proportionate share allotment of resulting company to\nshareholders of demerged company and there is no mention of any share valuation therein and\ntherefore the case sought to be made

VIDYA ONLINE PRIVATE LIMITED,PUNE vs. THE INCOME TAX OFFICER, WARD-13(5), PUNE

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

ITA 804/PUN/2025[2012-13]Status: DisposedITAT Pune09 Jan 2026AY 2012-13

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.804/Pun/2025 Assessment Year : 2012-13

For Appellant: Shri D.S. RahurkarFor Respondent: Smt.Sailee Dhole

Section 133(6)Section 143(3)Section 41(1)Section 68

firm carrying on a business or profession is succeeded by another firm, the other firm; (iv) where there has been a demerger, the resulting company.” 6 Vidya Online Private Limited 11. On going through the above provision, we have to find that whether the alleged liability ceased to exist

THERMO FISHER SCIENTIFIC INDIA P. LTD,MUMBAI vs. DCIT 15(3)(1), MUMBAI

ITA 7294/MUM/2018[2014-15]Status: DisposedITAT Mumbai02 Jan 2026AY 2014-15

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(3)Section 144C(13)Section 32(1)

purposes of its own business.\nExplanation 7A.—Where, in a demerger, any capital asset is transferred by\nthe demerged company to the resulting company and the resulting company\nis an Indian company, the actual cost of the transferred capital asset to the\nresulting company shall be taken ... section 170 or to the\namalgamating company and the amalgamated company in the case of\namalgamation, or to the demerged company and the resulting company in the\ncase of demerger, as the case may be, shall not exceed in any previous year\nthe deduction calculated at the prescribed rates

THERMO FISHER SCIENTIFIC INDIA P. LTD,MUMBAI vs. DCIT 15(3)(1), MUMBAI

ITA 7393/MUM/2017[2013-14]Status: DisposedITAT Mumbai02 Jan 2026AY 2013-14

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(3)Section 144C(13)Section 32(1)

purposes of its own business.\nExplanation 7A.—Where, in a demerger, any capital asset is transferred by\nthe demerged company to the resulting company and the resulting company\nis an indian company, the actual cost of the transferred capital asset to the\nresulting company shall be taken ... section 170 or to the\namalgamating company and the amalgamated company in the case of\namalgamation, or to the demerged company and the resulting company in the\ncase of demerger, as the case may be, shall not exceed in any previous year\nthe deduction calculated at the prescribed rates

THERMO FISHER SCIENTIFIC INDIA P. LTD,MUMBAI vs. DCIT 15(3)(1), MUMBAI

ITA 577/MUM/2017[2012-13]Status: DisposedITAT Mumbai02 Jan 2026AY 2012-13

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(3)Section 144C(13)Section 32(1)

purposes of its own business.\nExplanation 7A.—Where, in a demerger, any capital asset is transferred by\nthe demerged company to the resulting company and the resulting company\nis an indian company, the actual cost of the transferred capital asset to the\nresulting company shall be taken ... section 170 or to the\namalgamating company and the amalgamated company in the case of\namalgamation, or to the demerged company and the resulting company in the\ncase of demerger, as the case may be, shall not exceed in any previous year\nthe deduction calculated at the prescribed rates

THERMO FISHER SCIENFTIFIC INDIA P. LTD,MUMBAI vs. DCIT 15(3)(1), MUMBAI

ITA 1236/MUM/2016[2011-12]Status: DisposedITAT Mumbai02 Jan 2026AY 2011-12

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(3)Section 144C(13)Section 32(1)

purposes of its own business.\nExplanation 7A.—Where, in a demerger, any capital asset is transferred by\nthe demerged company to the resulting company and the resulting company\nis an indian company, the actual cost of the transferred capital asset to the\nresulting company shall be taken ... section 170 or to the\namalgamating company and the amalgamated company in the case of\namalgamation, or to the demerged company and the resulting company in the\ncase of demerger, as the case may be, shall not exceed in any previous year\nthe deduction calculated at the prescribed rates

J. M. HOUSING LIMITED,DELHI vs. PR. CIT (CENTRAL) KNP MEERUT, UTTAR PRADESH

In the result, the appeal of the assessee is allowed

ITA 8248/DEL/2025[2021-22]Status: DisposedITAT Delhi31 Dec 2025AY 2021-22

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2021-22] J.M. Housing Limited, Pr.Cit (Central) Kanpur, At Meerut, 312/3T/F5 Pratap Bhawan, Aayakar Bhawan, Bhainsali Ground, Bhahadur Shah Zafar Marg, Vs Meerut, Uttar Pradesh-25001 Central Delhi, Delhi-11002 Pan-Aaccj1692E Assessee Revenue

Section 133(6)Section 143(3)Section 263Section 271ASection 68

firm carrying on a business or profession is succeeded by another firm, the other firm; (iv) where there has been a demerger, the resulting company. Section-68 68. Where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, NOIDA, NOIDA vs. RAGHAV BAHL, NOIDA

In the result, appeal of the Revenue is dismissed

ITA 1640/DEL/2023[2020-21]Status: DisposedITAT Delhi19 Dec 2025AY 2020-21

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 139(1)Section 143(3)Section 250

arrangement was enclosed and para 8 of this scheme has been resorted for the swap ratio of 25 17 between demerged company and the resulting company. Thus the appellant claims that the cost of acquisition of 2,04 000 shares of M/s, TV18 Broadcast Ltd should be taken ... Arrangement is enclosed and para 8 of this Scheme has been resorted for the swap ratio of 25:17 between demerged company and the resulting company. Thus the appellant claims that the cost of acquisition of 9,09: 160 shares of M/s TVTB Broadcast Ltd should be taken

DCIT CENTRAL CIRCLE-1, NOIDA vs. RAGHAV BAHL, NOIDA

In the result, appeal of the Revenue is dismissed

ITA 1639/DEL/2023[2012-13]Status: DisposedITAT Delhi19 Dec 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 139(1)Section 143(3)Section 250

M/S GERA DEVELOPMENTS PVT. LTD,PUNE vs. PCIT (CENTRAL), PUNE, PUNE

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

ITA 1053/PUN/2024[2020-21]Status: DisposedITAT Pune09 Dec 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Hari KrishanFor Respondent: Shri Amol Khairnar

Section 143(2)Section 143(3)Section 263

amalgamating/demerged company) acquired it, i.e. NIL. 9.9.7 From the discussion made in foregoing paragraphs, it can be concluded that in the hands of the Resulting Company, in the amalgamation with respect to the instant case, the cost of the transferred capital asset to the amalgamated company shall be the same ... cost to the amalgamating company. The WDV of the block of assets acquired by Resulting Company will be the WDV of such assets in the hands of amalgamated company. Depreciation shall be apportioned between the amalgamating company and amalgamated company in the ratio of number of days for which those

ACIT, NEW DELHI vs. M/S. KCT PAPERS LTD., NEW DELHI

In the result, grounds raised by the revenue are dismissed

ITA 3380/DEL/2014[2008-09]Status: DisposedITAT Delhi05 Dec 2025AY 2008-09

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharmaacit, Circle 5 (1) Vs. M/S. Kct Papers Limited, New Delhi. Thapar House, 124, Janpath, New Delhi – 110 001. (Pan : Aacck4937D) (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Advocate Shri Deepesh Jain, Advocate Shri Tavish Verma, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 10.09.2025 Date Of Order : 05.12.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-Viii, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 21.03.2014For Assessment Year 2008-09. 2. Brief Facts Of The Case Are, The Assessee Company Belongs To The Thapar Group Established By Late Lala Karam Chand Thapar. There Was A Family Settlement Between The Various Constituents Of The Karam Chand Thapar Family As A Result Of Which Revenue-Organization/Restructuring Of The Group Dated 27Th April, 2001. The Re April, 2001. The Re-Organization Of The Group Companies & Trusts Organization Of The Group Companies & Trusts Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala K.C. Thapar. The Family Tree Of Karam Chand T K.C. Thapar. The Family Tree Of Karam Chand Thapar Family Is Explained As Hapar Family Is Explained As Under In The Form Of A Diagrammatic Chart: Under In The Form Of A Diagrammatic Chart:

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT DR

Section 391

Merchantile Limited (RMS), PML Merchantile Limited (PML) and JMK Merchantile Limited (JMK). Thus, the assessee company, M/s KCT Papers Ltd. is one of the resulting companies. 4. The various schemes of amalgamations and demergers have been duly approved and sanctioned by the Hon. High Court of Delhi and Bombay ... subsequently when the demerger took place in KCT Bros Ltd., this right was passed on to 4 (out of 7) of the resulting companies, assessee company being out of them. The aforesaid rights, title and interest were transferred to M/s TCG Urban Infrastructure Holding Ltd. for a total consideration

RAVI SHROFF,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX - 25(3), MUMBAI, BANDRA (EAST), MUMBAI

In the result, all remaining ground are allowed with the aforesaid directions

ITA 4186/MUM/2023[2015-16]Status: DisposedITAT Mumbai07 Nov 2025AY 2015-16

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 234BSection 234CSection 250Section 254(1)Section 28Section 28(1)

assessee as investment for more than twenty years. Further, the assessee was allotted equivalent no. of share in Vibrant Greentech Limited (VGT) the resulting company, whose name was subsequently change to HCL, pursuant to scheme of demerging. Thus, the assessee was holding 12,389 shares in HCL, being

RAMSAMY PONGIANNA GOUNDER DESAMANI,PALLIPALAYAM vs. ITD, WARD 2, , TIRUCHENGODE

In the result, appeal filed by the assessee is allowed

ITA 2438/CHNY/2024[2011-12]Status: DisposedITAT Chennai16 Oct 2025AY 2011-12

Section 139Section 147Section 148Section 151Section 2(22)(e)Section 250

{ "clean_text": "आयकर अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्नई\nIN THE INCOME TAX APPELLATE TRIBUNAL\n'B' BENCH, CHENNAI\nश्री एस

DCIT, RANGE-3, LUCKNOW vs. M/S. PRAYAGRAJ POWER GENERATION COMPANY LTD.,, NOIDA

In the result, ground no. 1 of appeal is dismissed and ground no

ITA 393/LKW/2020[2016-17]Status: DisposedITAT Lucknow15 Oct 2025AY 2016-17

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 115J

previous year or any of the preceding previous years and relatable to such asset or investment. (2B) In the case of a resulting company, where the property and the liabilities of the undertaking or undertakings being received by it are recorded at values different from values appearing in the books ... demerged company immediately before the demerger, any change in such value shall be ignored for the purpose of computation of book profit of the resulting company under this section. (2C) For a company referred to in sub-section (2A), the book profit of the year of convergence and each

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