DCIT Vs Mango Infratech Solutions Pvt. Ltd (ITAT Delhi)
The appeal before the Income Tax Appellate Tribunal (ITAT), Delhi Bench, was filed by the Revenue against the order of the Commissioner of Income Tax (Appeals)-3, Noida dated 10 July 2025 for Assessment Year 2013–14. The order of the CIT(A) arose from reassessment proceedings initiated under Section 147 of the Income Tax Act, 1961, and the reassessment order dated 18 December 2019.
The assessee was originally incorporated as a private limited company on 25 May 2010. Subsequently, the company was converted into a Limited Liability Partnership (LLP) under the name Mango Infratech Solutions LLP with effect from 16 October 2017. The original return of income for Assessment Year 2013–14 was filed by the company on 26 September 2013 declaring a loss of ₹93,431.
Based on information that the assessee had made investments amounting to ₹11,35,68,126, the Assessing Officer (AO) issued a notice under Section 148 on 30 March 2019 in the name of the erstwhile company. During the reassessment proceedings, the assessee informed the AO that the company had already been converted into an LLP and that jurisdiction over the assessee lay with another assessing authority. The assessee requested the transfer of the case accordingly. However, the AO rejected this request and relied on a judgment of the Allahabad High Court in Motor Sales vs. CIT. The AO proceeded to complete the reassessment on 18 December 2019 in the name of the erstwhile company and assessed total income at ₹7,43,72,640 by making an addition of ₹7,44,66,072 under the head “income from other sources.”
