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2012 (6) TMI 87 - HC - Income TaxValidity of reassessment notice issued for AY 1984-85, 1985-86, 1986-87 on ground that no amalgamation between M/s Modipon Ltd. and M/s Indofil Chemicals ltd. had taken place in the accounting years ended on 30.6.1983 and 30.6.1984 - effective date of amalgamation is 1st July, 1982 - Revenue contending date of amalgamation to be appointed date therefore, amalgamation took place after 31st March, 1986 - Held that:- It is undisputed that assessment for AY 84-85 and 85-86 were completed recording that the business income/earnings of Indofil Chemicals Ltd. was treated as income/earnings of chemical division of the Modipon Ltd. Further in AY 86-87 Tribunal decided in favor of assessee holding that amalgamation was effective from 1st July, 1982 and accordingly income of Indofil Chemicals Ltd. was assessable in the hands of the petitioner (Modipon Ltd.) on the basis of the scheme of amalgamation which was effective from 1st July, 1982. Since Tribunal order became final, petitioner is entitled to succeed in the present writ petitions and the reassessment notices issued are accordingly set aside and quashed.
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