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From the Courts »
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 ITO vs. Vikram A. Pradhan (ITAT Mumbai)

DCIT, Circle 7(1), New Delhi. Vs Sapient Consulting Ltd., Gurgaon, Haryana
November, 25th 2015
            IN THE INCOME TAX APPELLATE TRIBUNAL
                 DELHI BENCH `I 'NEW DELHI

      BEFORE SHRI CHANDRAMOHAN GARG, JUDICIAL MEMBER
                         AND
         SHRI O.P.KANT, ACCOUNTANT MEMBER

                 ITA NO. 1728/DEL/2014
                  ASSTT.YEAR: 2009-10

                  ITA NO. 1306/DEL/2015
                  ASSTT.YEAR: 2010-11

Sapient Consulting Limited,                  vs DCIT, Circle 7(1),
(Erstwhile Sapient Corporation Pvt. Ltd.),      New Delhi.
Tower B, First Floor,
Building 8, United Infospace,
Sector 2,Dundahera,
Gurgaon, Haryana-122016

                  ITA NO. 981/DEL/2014
                  ASSTT.YEAR: 2009-10

DCIT, Circle 7(1),             vs      Sapient Consulting Ltd.,
New Delhi.                             Gurgaon, Haryana
(Appellant)                            (Respondent)
      Appellant by: S/Shri Ajay Vohra, Sr. Adv. Neeraj Jain, Adv.
                    Sahil Mehta, Mrs. Nitya Gupta, CA
                   Respondent by: Ms Y. Kakkr, Sr. DR
                        Date of Hearing: 07.09.2015
                      Date of pronouncement: 23.11.2015

                         ORDER

PER C.M. GARG, JUDICIAL MEMBER

      These appeals by the assessee and the revenue have been preferred

against the assessment orders passed u/s 143(3) r/w section 144C of the Act in
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11

pursuance to the directions of the Dispute Resolution Panel-III, New Delhi (The

DRP) u/s 144C(5) of the Income Tax Act, 1961 (for short the Act) dated

19.12.2013 and 11.10.2014 for assessment year 2009-10 and 2010-11

respectively.


Additional grounds of the assessee in both the assessment years

2.     The assessee has proposed following additional grounds in both the

assessment years:-

            "1. That on the facts and circumstances of the case,
           assessment order framed under section 143(3) read with
           section 144C of the Income Tax Act, 1961 (`the Act') is
           beyond jurisdiction, bad in law and void ab initio.

           1.1 That on the facts and circumstances of the case, the
           assessing officer has erred in framing the assessment on a
           non-existent entity which was merged with Sapient
           Consulting Pvt. Ltd. w.e.f. April 1, 2011"



3.     We have heard the rival submissions and carefully perused the relevant

material placed on record before us. The ld. Senior counsel of the assessee

submitted that the assessment order dated 20.1.2014 u/s 143(3) r/w section

144C of the Act was passed in the name of Sapient Corporation Pvt. Ltd. (the

amalgamating company) which was non-existent entity on the date of passing

impugned said final assessment order since it was merged into Sapient

Consulting Pvt. Ltd. (the amalgamated company) vide Hon'ble Delhi High

Court order dated 12.10.2011 and 6.1.2012 and accordingly, the said order,

                                       2
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11

being void ab initio, is liable to be quashed. To support this contention, the ld.

Senior counsel has placed reliance on various orders/judgments of Hon'ble

Delhi High Court and Tribunals including judgement of Hon'ble Jurisdictional

Delhi High Court in the case of Spice Infotainment vs CIT (2012) 247 CTR

(Del) 500 and order of ITAT Delhi `D' Bench in I.T.A. No. 6452/Del/2013 for

assessment year 2006-07 (which was delivered by one of us viz. C.M. Garg,

JM) wherein the order of Hon'ble Delhi High Court in the case of Spice

Infotainment (supra) was followed while granting relief to the assessee.

Elaborating aforesaid facts of the case, the ld. Senior counsel of the assessee

placed request of the assessee for admission of additional grounds as

reproduced hereinabove in both assessment years i.e. assessment year 2009-10

and 2010-11 and submitted that in view of aforesaid position of law laid down

by various courts/Tribunals the appellant has raised said additional grounds of

appeal which raise a legal issue, not involving any fresh investigation into the

facts and based on the facts which are already placed on record. The ld. Senior

counsel placing reliance on the decision of Hon'ble Supreme Court in the

case of NTPC Ltd. Vs CIT 229 ITR 383 (S.C.) and pressing into service Rule

11 of ITAT Rules, 1963 the additional ground may kindly be admitted for

consideration and adjudication on merits.


4.     Ld. Ld. DR, replying to the above, contended that when the assessee

participated assessment proceedings despite merger, then no legal objection or


                                        3
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11

contention can be raised in this regard in the subsequent appellate proceedings.

Ld. DR strongly objected to the admission of additional grounds.


5.     Ld. Senior counsel also placed rejoinder and contended that on receipt of

the DRP/Assessing Officer final order, the assessee came to know about

illegality done by the authorities below wherein the assessment order was

passed against a non-existing entity i.e. amalgamating company.





6.     On careful consideration of above rival submissions, we are of the

opinion that the assessee did not raise this legal contention during proceedings

before the authorities below and participated in the proceedings but now this

legal issue has been raised before us by way of additional ground which

requires no further investigation of fact and which pertains to a legal issue and

facts pertaining to this legal and factual issue are already on record which goes

to the root of the matter. Merely because the assessee did not raise this legal

objection before authorities below does not take away the legal right of the

assessee to raise the same before higher appellate forum. Hence, in view of

dicta laid down by Hon'ble Apex Court in the case of NTPC vs CIT (supra), the

additional ground being mixed issue of law and facts is admitted for

consideration and adjudication on merits.




                                       4
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11

Adjudication of additional ground no. 1 & 1.1

7.     Apropos additional ground of the assessee, we have heard the rival

submissions and carefully perused the relevant material placed on record. Ld.

senior counsel of the appellant/assessee submitted that the appellant Sapient

Corporation Pvt. Ltd. (hereinafter referred to as `amalgamating company') was

incorporated on 9.3.2000 and was consistently being assessed in circle 7(1),

C.R. Building, New Delhi. On 13.11.2013, a new company in the name of

Sapient Consulting Pvt. Ltd. (hereinafter referred to as `amalgamated

company') was incorporated and the amalgamating company merged with new

amalgamated company under scheme of amalgamation u/s 391 and 394 of the

Companies Act 1956 in pursuance to order of Hon'ble Delhi High Court dated

12.10.2011 and 6.1.2012 w.e.f. the appointed date i.e. 1.4.2011. Ld. Senior

counsel further pointed out that in pursuance to aforesaid order, the appellant

company stood dissolved, without the process of winding up and copy of order

of Hon'ble High Court was also filed with the Registrar of Companies (ROC) on

18.11.2011. The learned counsel of the assessee contended that a letter was

filed before the Assessing Officer on 27.1.2012 intimating him merger of

assessee with amalgamating company. Learned counsel of the assessee fairly

submitted that the return was filed on 26.9.2009 by the amalgamating company

and the Assessing Officer issued notice u/s 143(2) of the Act on 18.8.2010

against the amalgamating company but after amalgamation w.e.f. 1.4.2011, the


                                       5
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11

Assessing Officer on 12.10.2012 issued notices against the assessee u/s 143(3)

and 142(1) against the amalgamating company and subsequently on 5.12.2012

& 13.2.2013, additional questionnaires were also issued to the amalgamating

company. The ld. Senior counsel vehemently contended that the Assessing

Officer passed draft assessment order u/s 144C of the Act on 22.3.2013 and the

final assessment order u/s 143(3) r/w section 144C of the Act was passed on

20.1.2014 in pursuance to the directions of the DRP dated 19.12.2013 in the

name of amalgamating company which was non-existent entity at the time of

issuing notices and passing impugned order of the DRP/Assessing Officer.


8.     The ld. Senior counsel pointed out that the impugned final assessment

order u/s 143(3) r/w section 144C of the Act was passed in the name of

amalgamating company which was non-existent entity since it was merged with

amalgamated company in pursuance to order of Hon'ble Delhi High Court dated

12.10.2011 and 6.1.2012 and thus said order being void ab initio is liable to be

quashed in view of proposition laid down by Hon'ble Jurisdictional Delhi High

Court in the case of CIT vs Spice Infotainment Pvt. Ltd. (supra).


9.     Replying to the afore noted submissions and contentions of the assessee,

the ld. Ld. DR contended that the orders/judgements as relied by the assessee

have been passed without considering the scheme of amalgamation, hence, ratio

of these orders/judgements are not applicable in the present case in hand.

Learned Departmental Representative also placed reliance on the judgment of

                                        6
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11

Hon'ble High Court of Delhi in the case of Yapi Kredi Bank (Deutschland)

vs Ashok k. Chauhan dated 17.1.2013 in FAO (OS) 511/2007, C.M. Appl

14878/2008 & 3645/2012 and submitted that the Hon'ble Jurisdictional High

Court, after referring to the dicta laid down by Hon'ble Supreme Court in the

case of Bhagwandass Chopra vs Untied Bank of India 1988 AIR 215 (S.C.),

has held that these proceedings will continue to operate against and also binding

on the transferee company or corporation in the same way in which they operate

against a person on whom any interest has devolved in any of the ways

mentioned in Rule 10 of order 22 of Civil Procedure Code 1908. Learned

Departmental        Representative   also       placed   reliance   on   following

orders/judgements:-


       i) Guduthur Bros vs ITO 40 ITR 298 (S.C.)

       ii) CIT vs Jagat Novel Exhibitors (P) Ltd. 356 ITR 559 (Del)
       iii) Venad properties (P) Ltd. vs CIT 340- ITR 463
        iv) Century Enka Ltd. vs DCIT 303 ITR (AT) 01 (Mumbai Tribunal)
         v) Chatturam & Others vs CIT 15 ITR 302 (Federal Court)

10.    On the basis of above noted orders/judgements, ld. Ld. DR further

elaborated his legal stand and submitted that in the case of Spice Infotainment

vs CIT (supra), the scheme of amalgamation as well as order of Hon'ble High

Court have not been considered.             Learned Departmental Representative

submitted that if for the sake of argument, it is found that the assessment has

been framed against non-existing entity, then the same is rectifiable u/s 292B of

                                            7
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11

the Act and no prejudice has been caused to the assessee who participated in the

entire assessment proceedings and explained his stand before the Assessing

Officer. Ld. DR also submitted that the case laws relied by the ld. Senior

counsel of the assessee in the case of CIT vs Micro Steels (P) Ltd. 232

Taxmann 102 and order of ITAT Delhi in the case of ACIT vs Dimension

Apparels in I.T.A. No.571 to 576/D/12 dated 21.6.13 are not applicable in the

light of dicta laid down by Hon'ble High Court in the case of Yapi Kredi Bank

(supra). Learned Departmental Representative pressing into service proposition

laid down by ITAT Mumbai in the case of Century Enka Ltd. vs DCIT (supra),

submitted that the order in the name of non-existing entity was passed on

account of ignorance of the fact of amalgamation and for this reason, the

assessment could not be held to be invalid and the right course was to set aside

the assessment and restore the matter to the file of the Assessing Officer with a

direction to re-frame the assessment in the correct name of the assessee.


11.    Learned counsel of the assessee placing rejoinder to the above contention

of the revenue has drawn our attention towards section 2(31) r/w section 4 of

the Act and submitted that as per section 4 of the Act, the charge of income tax

for any assessment year can be levied on a person and as per definition given in

section 2(31) (iii) of the Act, a person includes a company also. Learned

counsel of the assessee has further drawn our attention towards section 2(16) of

the Act and submitted that the meaning of amalgamation in relation to


                                        8
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11

companies means the merger of one or more companies with another company

or merger of two or more companies to form one company and the company or

companies which so merge being referred to as the amalgamating company or

companies and the company with which they merge or which is formed as a

result of merger as the amalgamated company formed as a result of merger as

the amalgamated company and from the date of merger the legal existence of

amalgamating company as a legal entity or person ceased to exist and order of

assessment passed against such non-existing entity or legal person cannot be

held as valid and the same should be annulled.


12.    Ld. Senior counsel vehemently contended that the assessee is not seeking

waiver of tax liability and the assessee fairly accepts that as per section 2(1B) of

the Act, the tax liability is fastened on the amalgamated company and hence the

assessee has raised legal objection that the assessment has been framed in the

name of non-existent entity on 21.2.14 despite the fact that the assessee by way

of letter dated 27.1.12 intimated the Assessing Officer about the merger of

assessee company with Sapient Consulting Pvt. Ltd., the amalgamated company

in pursuance to the order of Hon'ble Delhi High Court dated 12.10.11 censuring

merger of the assessee as per scheme of amalgamation u/s 391 to 394 of the

Companies Act, 1956 dated 6.1.12 w.e.f. the appointed date viz. 1.4.11 which is

also apparent from the scheme of amalgamation available at pages 79-80 of the

assessee's paper book. Ld. Senior counsel further pointed out that the assessee


                                         9
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11

is not challenging the validity of notice u/s 143(2) of the Act and hence, the

propositions relied by ld. Ld. DR and provisions of section 292B or 292BB of

the Act are not applicable to the case of the assessee.

13.    Learned counsel of the assessee has also drawn our attention towards

order of ITAT Delhi in the case of Impsat vs ITO reported as 91 ITD 354

(Del) and submitted that once the amalgamating company ceased to exist on the

appointed date, there was no question of assessing it for income tax as there is

no provision in the Act to assess addition which is dissolved. Ld. Senior

counsel lastly placed his reliance on the decision of Spice Infotainment vs CIT

and submitted that their lordships have explicitly held that the irresistible

conclusion would be that provisions of section 292B of the Act are not

applicable in such a case where the assessment has been framed in the name of

amalgamating company and the framing of assessment against a non-existing

person or entity goes to the root of the matter which is not a procedural

irregularity but a jurisdictional defect as there could not be any assessment

against a dead person.


14.    On careful consideration of above submissions, at the very outset, we find

it appropriate to note some admitted and undisputed facts that the assessee filed

its return of income in the name of amalgamating company on 26.9.09 and the

Assessing Officer issued notice on 18.8.2010 u/s 143(2). Subsequently on

12.10.11, the Hon'ble Delhi High Court passed an order sanctioning merger of

                                        10
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11

assessee with Sapient Consulting Ltd. an amalgamated company and on

18.11.11, the assessee filed form 21 along with copy of the Hon'ble Delhi High

Court order (supra) sanctioning the scheme of amalgamation with ROC and on

6.1.12 as per scheme of amalgamation and under Companies Act, the assessee

amalgamating company merged with Sapient Consulting Ltd. in pursuance to

the order of Hon'ble Delhi High Court w.e.f. 1.4.11 i.e. appointed date. It is

also important to note that on 27.1.2012, the assessee filed a letter before the

Assessing Officer intimating the merger of the company with Sapient

Corporation Pvt. Ltd., however, the Assessing Officer on 19.10.12 issued notice

u/s 143(2) along with notice dated 142(1) of the Act on the assessee

amalgamating company. After issuing additional questionnaires dated 5.12.12

and 13.2.13 on amalgamating company, the Assessing Officer on 22.3.13

passed draft assessment order u/s 144C of the Act on amalgamating company.

Finally, the Assessing Officer passed final assessment order u/s 143(3) r/w

section 144C of the Act on amalgamating company on 20.1.2014 in pursuance

to the directions of the DRP dated 19.2.13 u/s 144C(5) of the Act.


15.    In the light of above noted dates of events having taken place in the

present case, we proceed to decide the legal objection of the assessee against

validity of impugned assessment orders. At the very outset, we are required to

consider the ratio of the decision of Hon'ble High Court of Delhi in the case of

Spice Entertainment Ltd vs CST dated 3.8.2011 in I.T.A. No. 475-476 of 2011


                                       11
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11

wherein their lordships speaking for Hon'ble Jurisdictional High Court held as

follows:-





       "16. When we apply the ratio of aforesaid cases to the facts of
      this case, the irresistible conclusion would be provisions of s.
      202B of the Act are not applicable in such a case. The framing
      of assessment against a non- existing entity/person goes to the
      root of the matter which is not a procedural irregularity but a
      jurisdictional defect as there cannot be any assessment against
      a 'dead person'.

      17. The order of the Tribunal is, therefore, clearly unsustainable.
      We, thus, decide the questions of law In favour of the assessee
      and against the Revenue and allow these appeals.
       18. We may, however, point out that the returns were filed by M/s
       Spice on the day when it was in existence it would be permissible to
       carry out the assessment on the basis of those returns after taking
       the proceedings afresh from the stage of issuance of notice under s.
       143(2) of the Act. In substitute, the name of the appellant in place
       of M/s Spice and then issue notice to the appellant. However, such
       a course of action can be taken by the Assessing Officer only if it is
       still permissible as per law and has not become time-barred."

At the very outset, we respectfully note the dicta laid down by the Hon'ble High

Court that the provisions of section 292B of the Act are not applicable in such a

case where assessment has been framed in the name of non-existent

amalgamated company. Their lordships further held that the framing of

assessment against non-existent entity/person goes to the root of the matter

which is not a procedural irregularity but a jurisdictional defect as there cannot

be any assessment against a dead person. In the case of Spice Infotainment Ltd.

(supra), their lordships also pointed out that the returns were filed by M/s Spice

on the day when it was in existence. It would be permissible to carry out the


                                        12
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11

assessment on the basis of those returns after taking the proceedings afresh from

the stage of issuance of notice u/s 143(2) of the Act. It was also held that in

substitute the name of the appellant/amalgamated company in the place of

amalgamating company may be given and then notice may be issued as per

provisions of the Act.


16.    In the light of the ratio of the judgment of Hon'ble High Court in the case

of Spice (supra), when we analyze the facts and circumstances of the present

case, we clearly observe that undisputedly and admittedly, the return was filed

by amalgamating company on 26.9.2009. The Assessing Officer issued notices

u/s 143(2) of the Act in the name of amalgamating company on 18.8.2010.

Subsequently, letter dated 27.1.2012 was filed before the Assessing Officer,

during the course of assessment proceedings, informing the order of the Hon'ble

High Court dated 12.10.2011. However, the Assessing Officer issued notices

u/s 143(2) and 142(1) of the Act along with questionnaire on the amalgamating

company. After issuing said notices, the Assessing Officer issued additional

questionnaires on 5.12.2012 and 13.2.2013 on amalgamating company. The

Assessing Officer passed draft assessment order u/s 144C of the Act on

amalgamating company. Finally, the Assessing Officer passed final assessment

order u/s 143(3) r/w section 144C of the Act on amalgamating company in

pursuance to the directions of the ld. DRP dated 19.2.2013 u/s 144C(5) of the

Act.

                                        13
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11




17.    In the light of above noted facts, we clearly observe that the facts of the

present case are quite similar to the facts of the case of Spice (supra), wherein

their lordships have held that framing of assessment against non-existent

entity/person goes to the root of the validity of the assessment which is not a

procedural irregularity curable u/s 292B of the Act or under any other provision

of the Act but it is a jurisdictional defect because there cannot be framing of any

assessment order against a dead person or entity which is non-existent on the

date of framing/passing assessment order.




18.    Respectfully following the ratio of order of Hon'ble High Court in the

case of Spice Entertainment (supra), we are inclined to hold that the assessment

order dated 20.1.14 in the name of non-existent amalgamating company having

jurisdictional defect is not sustainable and therefore, we quash the same. It is

ordered accordingly. The additional ground no. 1 and 1.1 of the assessee for

Assessment Year 2009-10 are allowed.


19.    Since we have quashed assessment order being without valid jurisdiction,

the other grounds of the assessee become academic and infructuous and we also

dismiss the same being infructuous without any deliberations on merit.


                                        14
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11




Revenue's appeal in I.T.A. No. 981/Del/2014 for A.Y. 2009-10


20.    Since we have quashed assessment order dated 20.1.2014 by the earlier

part of this order, the Revenue's appeal arising from the same order does not

survive for adjudication and we also dismiss the same being infructuous.




Assessee's appeal I.T.A. No. 1306/Del/2015 for Assessment Year 2010-11


21.    The assessee has also raised additional ground in this appeal challenging

the jurisdiction of the Assessing Officer passing assessment order u/s 143(3) r/w

section 144C of the Act against non-existent entity. Except the date of filing

return and passing assessment order etc., the facts and circumstances of the

appeal of the assessee are quite similar and thus we order that our conclusion for

Assessment Year 2009-10 in the earlier part of this order will apply mutatis

mutandis to Assessment Year 2010-11 and hence, assessment order passed on

29.12.2014 is also quashed being passed against non-existent amalgamating

company.




                                       15
I.T.A. 1728, 1306/D/14 & 1306/D/15
Assessment year 2009-10, 2010-11




22.    In the result, appeals of the assessee for both the years are allowed and

appeal of the Revenue for Assessment Year 2009-10 is dismissed being

infructuous.


       Order pronounced in the open court on 23.11.2015.

           Sd/-                                                Sd/-

   ( O.P. KANT)                                          (C.M. GARG)
ACCOUNTANT MEMBER                                  JUDICIAL MEMBER

Dated: 23rd November, 2015
`GS'


Copy forwarded to:

1.     Appellant
2.     Respondent
3.     CIT 4.CIT(A)
5.     DR

                                                                 Asst. Registrar




                                       16

 
 
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