Dy. CIT v. Reliance Industries Ltd. (2026) 310 Taxman 406 (SC) Dy. CIT v. Reliance Industries Ltd. (2026) 310 Taxman 488 (SC) Editorial: Reliance Industries Ltd v. P.L.Roongta (2025) 171 taxmann.com 467/479 ITR 770 (Bom)(HC)

S. 143(3) Assessment-Merger-Additional evidence-Non-existent company-Additional grounds and evidence admitted by High Court-Order of assessment was quashed-SLP of revenue was dismissed.[S.260A, Code of Civil Procedure, 1908, Order 41, Rule 27, Art. 136,Art, 136]

Assessee-company, RIL and two other companies, namely, RRPPL and RRPPPL, had filed their respective returns of income. Subsequently, RRPPL and RRPPPL amalgamated with assessee. Thereafter, the Assessing Officer passed assessment orders in the name of RRPPL and RRPPPL. The  Assessing Officer had knowledge and was intimated about the fact of amalgamation of RPEL and RPPL with the assessee before the assessment order was passed. Additional grounds and evidence were filed in appeal before the High Court. High Court admitted the additional grounds and evidence.  High Court held that assessment orders were passed in the name of non-existing entities, even though the revenue was fully aware that such entities did not exist; therefore, assessment orders passed in the name of non-existing entities were void in law, and the same were quashed and set aside. SLP of revenue was dismissed.  AY. 1993-94 to 95-96)

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