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Case lawITAT › DCIT, Circle 7(1), Mumbai v. M/s. Piramal Enterprises Ltd. (ITAT Mumbai) — a scheme the High Court sanctioned cannot be attacked as a colourable device, but section 72A and Rule 9C still have to be satisfied
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DCIT, Circle 7(1), Mumbai v. M/s. Piramal Enterprises Ltd. (ITAT Mumbai) — a scheme the High Court sanctioned cannot be attacked as a colourable device, but section 72A and Rule 9C still have to be satisfied

The Assessing Officer says our merger was a device to buy the target's losses, even though the High Court sanctioned the scheme. How far does the sanction protect us, and what must we still prove?

The Assessing Officer says our merger was a device to buy the target's losses, even though the High Court sanctioned the scheme. How far does the sanction protect us, and what must we still prove?

The Tribunal held that once the scheme of merger has been duly approved by the High Court, having in mind the larger public interest, it cannot be disturbed by the Revenue merely by alleging that the merger was done only to buy losses and was a colourable device — the more so where the Income Tax department, being part of the Union of India which is a party to the scheme petition, filed no objection before the High Court and preferred no appeal under section 391(7) of the Companies Act, 1956. But the Tribunal did not stop there. It went on expressly to address "the next crucial aspect" — whether the assessee had complied with section 72A read with Rule 9C, "which alone would enable it to get the benefit of set off of accumulated losses of amalgamating company in addition to the scheme of merger approved by the Hon'ble Bombay High Court" — and found on the facts that the conditions and the Rule 9C production and Form No. 62 requirements were satisfied.

Decided by the ITAT (Shri Vikas Awasthy, Judicial Member and Shri M. Balaganesh, Accountant Member (Income Tax Appellate Tribunal, 'B' Bench, Mumbai)) on 2021-10-05, reported as ITA No. 4000/Mum/2007 and ITA No. 4345/Mum/2007 (ITAT Mumbai), with a third appeal, ITA No. 2238/Mum/2009, appearing in some renderings of the disposal; assessment year 2003-04; no law-report citation printed on the document. It bears on section 72A, section 72A(2), section 72 of the Income Tax Act 1961, in Assessment & Scrutiny, How Tax Law Is Read and Deductions & Disallowances matters.

Validity check could not be completed. Validity check could not be completed. I did not search for any later consideration of this order, and I did not check whether the Revenue took it further. Two matters limit its use quite apart from later treatment. First, the order reproduces section 72A(2) for assessment year 2003-04 as a three-condition provision corresponding to what the section calls clause (b), without the clause (a) conditions on the amalgamating company which the departmental Year 2003 edition prints; the order should not be cited on the content of section 72A(2). Second, the proposition that a sanctioned scheme cannot be attacked collaterally is drawn from the Companies Act, 1956 and section 391(7); it is not a holding that a sanction supplies the conditions of section 2(1B) or section 2(19AA), and the Tribunal in terms treated section 72A and Rule 9C as separate hurdles.

Why it matters

This order is useful precisely because it holds both halves of the line that this area of the law requires. The sanction of the scheme disposes of the genuineness attack: the Tribunal noted that the petition for sanction was filed on 15 January 2003, well after the slump sale of 1 November 2002 which the Departmental Representative said the amalgamation had been engineered to follow, so the factual premise of the colourable-device argument was wrong, and it added that a scheme sanctioned by the court has statutory force and can be challenged only by an appeal under section 391(7), not collaterally in an assessment. What the sanction does NOT do is supply the conditions of the Income-tax Act, and the Tribunal said so in terms by treating section 72A and Rule 9C as the provisions which "alone" would enable the set-off, "in addition to" the sanctioned scheme. A practitioner should carry both propositions or neither. There is a defect in the order that a reader must know about: at para 7.6 the Tribunal reproduced section 72A(2) "as it stood then as is relevant to A.Y.2003-04" as a provision stipulating three conditions, and the text it set out is the three conditions on the AMALGAMATED company — what the section calls clause (b) — with no separate mention of the clause (a) conditions on the amalgamating company. The departmental Year 2003 edition of section 72A prints the clause (a)/(b) structure. The consequence is that the order should not be cited as authority on the content of section 72A(2), and a reader relying on it must still test the clause (a) conditions independently.

Binding on the AO and CIT(A) within the Tribunal's jurisdiction. Persuasive elsewhere.

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