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Mallelil Industries Pvt. Ltd. vs. The Income Tax Officer

Case No: ITA No. 557/Coch/2023 & SA No. 117/Coch/2023
Court: Income Tax Appellate Tribunal, Cochin Bench
Date: 26 Sept 2024

Parties Involved

appellantMallelil Industries Pvt. Ltd.
respondentThe Income Tax Officer

Facts Summary

Mallelil Industries Pvt. Ltd. (MPPL) was incorporated in September 2013 and amalgamated with the assessee in March 2019. The assessee set off the loss of the amalgamating company amounting to Rs. 1,02,06,393.00 under section 72A of the Income Tax Act, 1961. However, the Assessing Officer disallowed the set off as the amalgamation occurred within three years of incorporation. The assessee appealed against this decision. The appeal was filed with a delay, which was condoned by the tribunal. The main issue was whether the Revenue could disallow the set off of the loss of the amalgamating company in the year under consideration.

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Whether the Revenue can disallow the set off of the loss of the amalgamating company in the year under consideration.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

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