TaxTMI 
TaxTMI 
2024 (4) TMI 1218
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....ase of our clients for income-tax assessment year 2018-19. served through e-filing portal on even date (b) Our clients were not aware that the NFAC has passed the order and uploaded the same on the e-filing portal (c) On taking updates of pending income-tax matters of the Group towards the end of January, 2023, the management of our clients noticed that the NFAC has already passed an order for assessment year 2018-19, and partially allowed the appeal. (d) that the management immediately sent the order to the accounts team for further action and to prepare and file an appeal to the Income-tax Appellate Tribunal. Further, it would not be out of place to mention that there is absolutely no mala fide intention on the part of our clients for the aforesaid delay. No benefit would accrue to them on account of not filing of appeal within the due date. As such, you will appreciate that the error in not filing of appeal is, on facts, bona fide. In view of the above, we on behalf of our clients urge you to condone the delay in filing the appeal under reference and admit the same for disposal on merits. Please find enclosed an Affidavit of the Manag....
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....the Assessee has been estimated after rejection of the books of accounts, the A.O. could not make disallowance of the same books of account by invoking provisions of Section 40(a)(ia) of the Act." 4. Whereas the Revenue has raised the following grounds:- "1. On the facts and in the circumstances of the case and in law the Id. CIT (Appeals) was not justified in allowing claim of deduction u/s 801A of the Act amounting to Rs. 10,14,22,382/-"? 2. "On the facts and in the circumstances of the case and in law the Ld. CIT (Appeals) failed to appreciate the fact that the assessee has not fulfilled the conditions laid down for claiming deduction u/s 801A of the Act"? 3. "On the facts and in the circumstances of the case and in law the Ld. CIT (Appeals) failed to appreciate that the assessee was involved in carrying out work in the nature of rehabilitation whereas there is no reference to the term "road widening" anywhere in Work Order and has not carried out any work of development of new infrastructure facility or maintaining the same"? 4. "On the facts and in the circumstance of the case and in law the ld. CIT (Appeals) failed to appreciate the fact....
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....nds of appeal." 6. Since the legal issue raised by the assessee challenges the very validity of the order, that order has been passed in the case of a non-existent entity as much as erstwhile company M/s. M.B. Patil Constructions Ltd. has been amalgamated with Patil Constructions and Infrastructure Ltd w.e.f. 01/04/2018 and therefore, the issuance of notice u/s. 143(2) as well as the order passed by the AO is bad in law and deserves to be quashed. 7. The brief facts qua the legal issue raised are that, M/s. M.B. Patil Constructions Ltd was incorporated on 23/01/2003, which was mainly engaged in the business of execution of civil infrastructure development contracts and had filed its return of income on 30/11/2018 for A.Y. 2018-19 admitting total income of Rs. 13,01,48,180/- after claiming deduction u/s. 80IA of Rs. 10,14,22,382/-. It has also declared share profit from joint venture of PCIPL and MBPCL of Rs. 12,11,123/- which was not taxable in the hands of the assessee company being share profit. The assessment order u/s. 143(3) r.w.s. 144B was completed on 26/07/2021 in the name of M/s. M.B. Patil Constructions Ltd., which had ceased to exist at the time of assessment proce....
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....uki India Ltd (2019) 416 ITR 613 and PCIT vs. Mahagun Realtors (P) Ltd. reported in 287 taxmann 566. He also relied upon the Coordinate Bench decision of ITAT in the case of ACIT vs. M/s. Candor Renewable Energy Pvt. Ltd in ITA Nos. 2561/Mum/2021 & 2560/Mum/2021 and others order dated 19/10/2022, wherein the Tribunal has discussed both the judgments of the Hon'ble Supreme Court including M/s. Mahagun Realtors (P) Ltd.(supra) and have explained entire concept of law on this point. 11. On the other hand, ld. DR submitted that assessee has filed the return of income in the name of M/s. M.B. Patil Constructions Ltd. and since assessee's case was covered under CASS parameters which were identified from ITR filed by the assessee on 30/11/2018 and since return was selected for scrutiny, it has picked up the PAN and name mentioned in the ITR. Further, the notices were delivered on the e-mail ID mentioned in the said ITR that [email protected]. He further submitted that not only the notices were valid but also the conduct of the assessee during the assessment proceedings is also misleading and in his written submissions he has highlighted the following points:- 3....
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....itself as an existent entity throughout the first appellate proceedings. Though the entity ceased to be in existence, in law, yet appeals were filed on its behalf before the CIT(A) and the ITAT. After fully participating in the first appellate proceedings, for the first time, that too eight months after filing of the appeal an additional ground was raised before the ITAT, that the notice u/s 143(2) was issued and assessment order was made on non-existent entity. 3.4 The conduct of the amalgamated company during the assessment proceedings was lacking in propriety. 3.4.1 At the stage of assessment and first appellate proceedings, the amalgamated entity i.e Patil Construction and Infrastructure Ltd did not participate in the course of the proceedings. The facts related to the amalgamation and the continuance of assessment proceedings of amalgamating entity in its own name were never brought to the notice of the A.O or the CIT(A). IL was never plainly stated that the meet was not in existence. This was despite the fact that it was incumbent upon the successor of the assessee to represent the assessee in the proceedings before the tax authorities. 3.5 The orig....
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....rties and perused the relevant records on the additional ground raised by the assessee. It is not in dispute that M/s. M.B. Patil Constructions Ltd. was amalgamated with M/s Patil Constructions and Infrastructure Ltd. by the order of NCLT dated 29/11/2018 approving the scheme of merger w.e.f. 01/04/2018. It is on record that assessee had communicated this fact vide letter dated 27/07/2018 filed on 02/08/2018, both by erstwhile company M.B. Patil Construction Ltd. and also by M/s. Patil Constructions and Infrastructure Ltd about the proposed scheme of merger and also intimated to the ld. AO that M/s. Patil Constructions and Infrastructure Ltd. alongwith copy of NCLT order as per the letter incorporated above. The said letter bears the receiving stamp of the office of the Dy. Commissioner of Income Tax (2)(3) i.e. the Assessing Officer. Nowhere in the assessment order, the ld. AO has mentioned about this fact that this company is no longer in existence and has already amalgamated with another company, M/s. Patil Constructions and Infrastructure Ltd. The case of the Revenue before us is that, firstly, the return of income was selected by computer aided scrutiny selection which has pic....
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..... 01/04/2018, so at least post 29/11/2018, when parties came to know about the merger, then locus standi of amalgamating company ceases to exist and all the proceedings then has to be in the name amalgamate company. It is the duty of the ld. AO that once the intimation has been given to him twice and brought on record, then he should have ensured that notice issued by him u/s. 143(2) is in the name of correct entity and not on a non-existing entity which already stood amalgamated. This co-ordinate Bench in the case of M/s. Candor Renewable Energy Pvt. Ltd (supra) after discussing the provisions of the Act specially Section 170 of the Companies Act and the effect of amalgamation / merger as per the Companies Act and the judgments relevant on this issue including the judgment of the Hon'ble Apex Court in the case of General Radio & Appliances Co. Ltd. & Ors vs. M.A. Khader reported in 2 SCC 656 and judgment of the Hon'ble Supreme Court in the case of Saraswati Industrial Syndicate Ltd. vs. CIT reported in 186 ITR 278., have explained in the following manner:- "16. Section 302 of the Companies Act, 2013 (earlier section 431 of the Companies Act, 1956) relates to dissolution o....
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....ts including leasehold and tenancy rights held by the transferor company blended with the transferee company, therefore, the transferee company was legal tenant and there was no question of any subletting. The Hon'ble Apex Court held that under the order of amalgamation made on the basis of the High Court's order, the transferor company ceased to be in existence in the eye of law and it effected itself for all practical purposes. United Kingdom Court in the case of M.H. Smith (Plant Hire) Ltd. Vs. D.L. Mainwaring (T/A Inshore), 1986 BCLC 342 (CA), in the context of dissolution of a company that "once a company is dissolved it becomes a nonexistent party and therefore no action can be brought in its name. Thus an insurance company which was subrogated to the rights of another insured company was held not to be entitled to maintain an action in the name of the company after the latter had been dissolved". 18. The aforesaid principle laid down in General Radio & Appliances Co. Ltd. (supra) was affirmed by the Hon'ble Apex Court in the case of Saraswati Industrial Syndicate Ltd. Vs. CIT 186 ITR 278 (SC). Briefly, the facts giving rise to this appe....
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....d since the assets of both the companies were merged and blended to constitute a new company, the liabilities attaching thereto must, therefore, be on the amalgamated company. On these findings, the High Court held that the amalgamated company, namely, the assessee, was liable to pay tax on Rs. 58,735. The Apex court considered the question whether, on the amalgamation of the Indian Sugar Company with the appellant company, the Indian Sugar Company continued to have its identity and was alive for the purposes of section 41(1) of the Act. The Apex court observed as under :- "Generally, where only one company is involved in a change and the rights of the shareholders and creditors are varied, it amounts to reconstruction or reorganization or scheme of arrangement In an amalgamation, two or more companies are fused into one by merger or by one over the other. Reconstruction or amalgamation has no precise legal meaning. Amalgamation is a blending of two or more existing undertakings into one undertaking, the shareholders of each blending company become substantially the shareholders in the company which is to carry on the blended undertakings. There may be amalgamatio....
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....an amalgamating company which has been amalgamated and has been dissolved is null and void or whether the framing of an assessment in the name of such company is merely a procedural defect which can be cured. The Hon'ble Delhi High Court held as follows: (a) Spice (amalgamating company) got amalgamated with M Corp Pvt. Ltd. It was the result of the scheme of the amalgamation filed before the Company Judge of Delhi High Court which was duly sanctioned vide orders dated 11th February, 2004. With amalgamation made effective from 1st July, 2003, Spice ceased to exist. That is the plain and simple effect in law. (b) The scheme of amalgamation itself provided for this consequence, inasmuch as simultaneous with the sanctioning of the scheme, Spice also stood dissolved by specific order of Delhi High Court. With the dissolution of the amalgamating company, its name was struck off from the rolls of Companies maintained by the Registrar of Companies. (c) A company incorporated under the Indian Companies Act is a juristic person. It takes its birth and gets life with the incorporation. It dies with the dissolution as per the provisions of the Companies Act. It is tr....
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.... India Ltd (MSIL). b) SPIL filed return declaring certain taxable income, which was processed u/s 143(1). c) Subsequently, SPIL (Amalgamating Company) was amalgamated with 'MSIL' (Amalgamated Company) with effect from 1-4-2012 under Court orders on 29.01.2013. d) MSIL intimated to the AO on 2.04.2013. e) Notice under section 143(2) dated 26.09.2013 was issued to SPIL, non-existent entity. f) Thereafter, MSIL participated in assessment proceedings of SPIL. g) The assessment order under section 143(3), read with section 144C (1) of the Act was passed in the name of "SPIL (amalgamated with MSIL)". The assessee argued before the tax/ appellate authorities that an assessment order passed in the name of a non-existent entity was void ab initio, since after amalgamation, the amalgamating company ceases to exist. Tax Department was of the view that since name of both the entities were mentioned in the order, the assessment order cannot be declared as invalid. Before the Apex Court, the main contentions of the Revenue were as follows: (a) Names of both amalgamating and amalgamated company was mentioned in the as....
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....he Act. Consequently, there was no requirement to pass a draft assessment order/reference to DRPetc.; g) The final assessment order dated 31 October 2016 is beyond limitation in terms of Section 153(1) read with Section 153 (4) of the Act. h) The assessment framed in the name of the amalgamating Company is invalid [refer: Spice Entertainment vs. CIT, CIT v. Dimension Apparels (P.) Ltd. [2015] 370 ITR 288 (Delhi); affirmed by Hon'ble Apex Court vide Civil Appeal No. 3125 of 2015, CIT v. Micron Steels (P.) Ltd. 372 ITR 386 (Delhi), CIT v. Micra India (P) Ltd. 231 Taxman 809 (Delhi)]. i) Assessment framed in the case of a non-existent entity is non-est in the eyes of law [refer: Pr. CIT vs. BMA Capfin Ltd. [2018] 100 taxmann.com 329 (Delhi) (Revenue's SLP dismissed against the same in Pr. CIT vs. BMA Capfin Ltd. [2018] 100 taxmann.com 330/[2019] 260 Taxman 89 (SC)] The Apex Court after taking into consideration submissions of both sides held as follows: a) Under the approved scheme of amalgamation, the transferee assumed the liabilities of the transferor company, including tax liabilities; b) The consequence of the scheme o....
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....original return of income was not revised even though the assessment proceedings were pending. The last date for filing the revised return was 31.03.2008, after the amalgamation order came into operation. iv. A search and seizure proceeding was conducted in respect of the Mahagun group, including the MRPL and other companies. v. When search and seizure of the Mahagun group took place, no indication was given about the amalgamation. vi. A statement made on 20.03.2007 by Mr. Amit Jain, MRPL's managing director, during statutory survey proceedings under Section 133A, unearthed discrepancies in the books of account, in relation to amounts of money in MRPL's account. The specific amount admitted was 5.072 crores, in the course of the statement recorded. vii. The warrant was in the name of MRPL. The directors of MRPL and MIPL made a combined statement under Section 132 of the Act, on 27.08.2008. viii. A total of Rs. 30 crores cash, which was seized- was surrendered in relation to MRPL and other transferor companies, as well as MIPL, on 27.08.2008 in the course of the search operation, when a statement of Mr. Amit Jain was recorded unde....
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....ty. ii. In other words, the business and the adventure lives on but within a new corporate residence, i.e., the transferee company. It is, therefore, essential to look beyond the mere concept of destruction of corporate entity which brings to an end or terminates any assessment proceedings. There are analogies in civil law and procedure where upon amalgamation, the cause of action or the complaint does not per se cease - depending of course, upon the structure and objective of enactment. Broadly, the quest of legal systems and courts has been to locate if a successor or representative exists in relation to the particular cause or action, upon whom the assets might have devolved or upon whom the liability in the event it is adjudicated, would fall. iii. The combined effect, therefore, of Section 394 (2) of the Companies Act, 1956, Section 2 (1A) and various other provisions of the Income Tax Act, is that despite amalgamation, the business, enterprise and undertaking of the transferee or amalgamated company- which ceases to exist, after amalgamation, is treated as a continuing one, and any benefits, by way of carry forward of losses (of the transferor company), depr....
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.... the present case, the participation in proceedings was by MRPL which held out itself as MRPL. vii. What is overwhelmingly evident- is that the amalgamation was known to the assessee, even at the stage when the search and seizure operations took place, as well as statements were recorded by the revenue of the directors and managing director of the group. A return was filed, pursuant to notice, which suppressed the fact of amalgamation; on the contrary, the return was of MRPL. Though that entity ceased to be in existence, in law, yet, appeals were filed on its behalf before the CIT, and a cross appeal was filed before ITAT. Even the affidavit before this court is on behalf of the director of MRPL. Furthermore, the assessment order painstakingly attributes specific amounts surrendered by MRPL, and after considering the special auditor's report, brings specific amounts to tax, in the search assessment order. That order is no doubt expressed to be of MRPL (as the assessee) - but represented by the transferee, MIPL. All these clearly indicate that the order adopted a particular method of expressing the tax liability. The AO, on the other hand, had the option of making a com....
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.... even in the first appeal before the Id. CIT (A) and cross objection before the ITAT, it was mentioned as "MRPL represented by MIPL". At no point of time, even at the time of search and subsequently on receipt of the notice, it was stated that MRPL was not in existence and its business of the erstwhile MRPL was taken over by MIPL. Even in the counter affidavit filed before the Hon'ble Apex Court, it has been affirmed by Shri Amit Jain, who has been described in the affidavit as Director of M/s. Mahagun Realtors (P) Ltd.. It was in this background, the Hon'ble Court in para 33 observed as under - "33. There is no doubt that MRPL amalgamated with MIPL and ceased to exist thereafter; this is an established fact and not in contention. The respondent has relied upon Spice and Maruti Suzuki (supra) to contend that the notice issued in the name of the amalgamating company is void and illegal. The facts of present case, however, can be distinguished from the facts in Spice and Maruti Suzuki on the following bases." 26. Therefore, the Supreme Court merely distinguished the facts in Spice and Maruti, while continuing to agree with the fundamental principle that on a....
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....e following grounds: a) The legislative amendment by way of introduction of section 2(1A), defining "amalgamation", was not taken into account by the Apex Court in earlier decisions. Further, the tax treatment in case of amalgamation under various provisions (such as in section 72A, 80IA, etc.) of the Act were not brought to the notice of the Apex Court, in the earlier decisions; b) In the relied upon cases, the assessee had duly informed the tax authorities about the fact of the merger of companies and yet the assessment order was passed in the name of the non-existent entity. However, in the present case, the assessee failed to inform the assessing officer about the amalgamation for assessment year 2006-07 (year in dispute), though disclosure was made for subsequent years (AYs 2007-08 and 2008-09). The return of income filed on 28.05.2010 (post amalgamation) pursuant to notice under section 153A was filed in the name of MRPL and the fact of business reorganization was mentioned as 'not applicable" in the return form. c) In relied upon cases, the amalgamated companies participated in the assessment proceedings before the tax department in their own c....
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....r company; (b) by deeming fiction- through several provisions of the Act, the treatment of various issues, is such that the transferee is deemed to carry on the enterprise as that of the transferor. d) Combined effect of Section 394 (2) of the Companies Act, 1956, Section 2 (1A) and various other provisions of the Income Tax Act, is that despite amalgamation, the business, enterprise and undertaking of the transferor or amalgamating company- which ceases to exist, after amalgamation, is treated as a continuing one, and any benefits, by way of carry forward of losses (of the transferor company), depreciation, etc., are allowed to the transferee. Therefore, unlike a winding up, there is no end to the enterprise, with the entity. The enterprise in the case of amalgamation continues. e) Whether corporate death of an entity upon amalgamation per se invalidates an assessment order ordinarily cannot be determined on a bare application of Section 481 of the Companies Act, 1956 (and its equivalent in the 2013 Act) but would depend on the terms of the amalgamation and the facts of each case. 29. The Apex Court with the aforesaid observations, quashed the order of t....
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....albeit its facts are clearly covered by the judgment of Apex Court in the case Maruti Suzuki India Ltd. (supra). Here right from the day one, the AO was brought to the notice and as was brought on record before him that the erstwhile entity M/s Bhadrawati Ispat & Energy Ltd had already stood amalgamated with M/s Reliable Record Keepers Pvt. Ltd. w.e.f. AY 2015-16 only and still he continued with the proceedings u/s 153A in the name of non-existing entity. Thus the entire proceedings including notice u/s 153A and also statutory notice issued in the name of non-existing entity was void ab initio. Consequently, the entire proceeding was illegal. Even the assessment order though which has been captioned as "M/s Bhadrawati Ispat & Energy Ltd. (merged with M/s. Reliable Record Keepers Pvt. Ltd. which has now known as M/s. Candor Renewable Energy Private Limited" is in fact in the name of non-existing entity only. Therefore, the reasons and principles laid down by the Hon'ble Apex Court in the case of Maruti Suzuki India Ltd. (supra) is applicable and accordingly assessment orders passed by the AO are invalid and non est. 32. Accordingly, we hold that the entire assessment order ....
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....y. The High Court upheld the order passed by the Tribunal and the SLP filed against the decision of the High Court was dismissed. 18.1 The assessee had indicated that it underwent a change. The original assessment was completed, but the matter was remanded on two occasions and in the third round, the assessee had indicated how it had underwent the change. The decision of Spice Entertainment v. CST [IT Appeal No. 475 of 2011, dated 3-8-2011] had been referred to, to hold that once the corporate entity is merged with another, i.e., transferee corporation or entity, the assessment had to be completed in the later's hands. The appeal was dismissed, as no substantial question of law was there to consider. 18.2 The decision also makes it quite clear that the assessment when initiated in the name of the transferor company and before it gets completed, if the company goes into amalgamation and the Revenue still continues to assess the transferor company and not the transferee company, it is a nullity. 19. The decision of the Apex Court in the case of Pr. CIT v. Mahagun Realtors (P.) Ltd. [2022] 137 taxmann. Com 91/287 Taxman 566, requires serious consideratio....
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....he complaint does not per se cease, depending of course, upon the structure and objective of enactment. Broadly, the quest of legal systems and Courts has been to locate if a successor or representative exists in relation to the particular cause or action, upon whom the assets might have developed or upon whom the liability in the event it is adjudicated, would fall. 20.1 While distinguishing the decision of Maruti Suzuki India Ltd. (supra), the Court notices that the scheme of amalgamation was approved on 29-1-2013 with effect from 1-4-2012 and the same was intimated to the Assessing Officer on 2-4-2013 i.e. on the very next day and the notice under section 143(2) for the Assessment Year 2012-13 was issued to amalgamating company on 26-92013. Thus, the notice was issued to non-existing company and the assessment order was issued against the company, which was held to be substantive illegality and not procedural violation of the nature adverted to in section 292B. 20.2 In Maruti Suzuki India Ltd. (supra), the Court had further noticed that the Assessing Officer was informed of the amalgamating company having ceased to exist as a result of approved scheme of amalga....
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....t Years 2007-08 to 2008-09, a separate proceedings against MIPL and the proceedings against MRPL for these two assessment years were quashed by the Additional CIT by order dated 30-11-2010, as the amalgamation was disclosed. 20.4 What overwhelmingly evident was that the amalgamation was known to the assessee, even at the stage when the search and seizure operations took place as well as statements were recorded by the Revenue of the Directors and Managing Director of the group. A return was filed, pursuant to the notice, which suppressed the fact of amalgamation and, in fact, the return was filed by MRPL though the entity was ceased to exist and yet the appeals were filed before the CIT and the Tribunal. Even the affidavit was filed before this Court on behalf of the Director of MRPL. The assessment order attributes specific amounts surrendered by MRPL and after considering the special auditor's report, brings specific amounts to tax in the search assessment order. 20.5 All these clearly indicate that the order adopted a particular method of expressing the tax liability. And hence, the Court held that whether the corporate death of an entity upon amalgamation ....
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....Business of GFL Limited, the Petitioner First Transferee/De-merged company to Inox Wind Energy Limited, the Petitioner Resulting/Second Transferee Company ( Part III of the Scheme) was approved by the Hon'ble National Company Law Tribunal, Ahmedabad Bench ("NCLT") vide its order dated 25th January, 2021. The Scheme has become effective upon filing of the certified copy of the Order passed by NCLT sanctioning the Scheme, with the Registrar of Companies, Gujarat (MCA website) today i.e. 9th February, 2021, with effect from the Appointed Date of 1st April, 2020 for Part II of the Scheme and 1st July 2020 for Part II of the Scheme. Consequent to the Scheme becoming effective, Inox Renewables Limited stands dissolved without the process of winding up and Inox Wind Energy Limited is now the Holding and Promoter Company of Inox Wind Limited with effect from 0th February, 2021. Copy of the Order passed by NCLT dated 25th January, 2021 along-with copy of the Scheme is attached herewith for ready reference. This is for your information and needful consequential actions in the matter." 21.1 This makes it abundantly clear that the scheme has bee....
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....aming of assessment in the name of such companies is not merely a procedural difficulty, which can be cured. Amalgamated company had already brought the facts of amalgamation to the notice of the Assessing Officer and yet he chose not to substitute the name of the amalgamated company and proceeded to make the assessment in the name of non-existing company and thereby rendering it void. This surely could not be said to be a procedural difficulty on 23-9-2021. The show cause notice-cum-draft assessment order when was issued in the name of the non-existing company giving a very short period for the company to reply, the very objection was raised by the amalgamated company pointing out that the assessment was in the name of the non-existing company. Repeated objections on the part of the petitioner had fallen on deaf ears and no heed was paid to various correspondences addressed to the respondent department. It is not being disputed that the order of NCLT and all the requisite documents were furnished to the authority by the amalgamated company and it had virtually implored to discontinue the proceedings against the non-existing company. 23. On the issue of prejudice also, we ....
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....d appeal of the assessee is allowed. 19. Since, we have quashed the assessment order, the grounds on merits raised by both the parties have become purely academic and infructuous. 20. In the result, appeal of the assessee is allowed and appeal of the Revenue is dismissed. Order pronounced on 16th April, 2024. ============= Document 1 PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED Formerly know PATIL CONSTRUCTION INFRASTRUCTURE LIMITED) CIN U45202MH2010PLC200931 Corporate Off Floor, PMPML Commercial Building No. 1. Shankar Road Opp. Income Tax Building, Swargate, Pune-411042 (MH) Ph: 020-24479626 / 24479978/79/80 Fax: 020 - 24479625 E-mail: panigroup pattlerwisp.coin Dalm Ref. Now CIN: 045202MH2010PLC200931 To Deputy Commissioner of income Tax Circle 1(2)(2), Ayakar Bhawan, M.K.Road, Mumba आपल 23 JAN 2019 Date: 22.01.2019 2 400020. OFFICE OF THE DY, COMMISSIONER OF INCOME TAX T'121 (2) Subject: Intimation of Merger of M B Patil Constructions Limited Constructionand Infrastructure Limited. PAN Number: A) M B PATIL CONSTRUCTION LTD: AAECM0806B with Patil B) PATIL CONSTRUCTION ....