Reliance Industries Ltd. v. P. L. Roongta, CIT

Introduction

The dispute arose from assessment orders passed by the Income Tax Department under Section 143(3) against several companies that had already ceased to exist due to their amalgamation with Reliance Industries Limited (RIL). The schemes of amalgamation had been duly sanctioned by the competent Court, pursuant to which the transferor companies stood dissolved without winding up and all their assets, liabilities, rights and obligations vested in RIL.

The Department had been informed about the amalgamations, including the effective dates and supporting documentation. Despite possessing this information, the Assessing Officer continued the assessment proceedings and passed assessment orders in the names of the amalgamating (transferor) companies instead of the surviving amalgamated company, RIL.