Case Details
Case Name: In the matter of Scheme of Amalgamation between M/s Lakshmi Technosolutions Private Limited and M/s Srijayalakshmi Automotives Private Limited
Court/Authority: National Company Law Tribunal, Hyderabad Bench - I
Case Number: CP (CAA) No. 48/230/HDB/2025 connected with C.A. (CAA) No.33/230/HDB/2025
Date of Order: 20.05.2026
Period of Dispute: Scheme implementation with Appointed Date 01.10.2024
Parties Involved
Petitioners:
- M/s Lakshmi Technosolutions Private Limited (Transferor Company) [CIN: U45100TG2003PTC041833]
- M/s Srijayalakshmi Automotives Private Limited (Transferee Company) [CIN: U34300TG1998PTC029447]
- Their respective shareholders and creditors
Regulatory Authorities Involved:
- Income Tax Department
- Official Liquidator
- Regional Director (SER)
Tribunal Members:
- Shri Rajeev Bhardwaj, Hon'ble Member (Judicial)
- Shri Sanjay Puri, Hon'ble Member (Technical)
Legal Representation:
- Ms. Grishma Kalantri, Ld. PCS for the Petitioner
Issues / Allegations / Violations
The petition sought sanction of Scheme of Amalgamation under Sections 230-232 of Companies Act, 2013. Key issues raised by regulatory authorities:
Income Tax Department Observations:
- Pending demand of ₹3,57,69,540 against Transferor Company for AY 2017-18, 2018-19, and 2019-2020
- Pending demand of ₹5,81,50,380 against Transferee Company for earlier assessment years
- Requested Tribunal to ensure resultant company liable for all dues
Official Liquidator Observations:
- Record date determination power vested solely with Amalgamated Company's Board
- Employee protection clause wording concerns
- Appointed Date of 01.10.2024 considered old without proper justification
- Authorized capital clubbing not compliant with Section 232(3)(i) of Companies Act
- 1:1 share exchange ratio questioned given Transferor Company's loss-making status
- Accounting treatment inconsistency with AS-14 requirements
- Valuation report adequacy concerns
Regional Director (SER) Observations:
- Statutory compliance assurance required
- Tax liability undertaking needed
- Object dissimilarity between companies
- Tax implications of loss-making company merging with profit-making company
- Loans to interested parties compliance with Sections 185/186/188
- Open charges pending
- Books preservation requirement
- Offences liability continuation
- Rule 17(2) compliance requirement
Findings & Observations
The Tribunal examined all material on record and found:
- No tenable objections raised by regulatory authorities
- Petitioner Companies undertook to comply with all observations
- Scheme not opposed to public interest
- Proposed Scheme in interests of both companies and their stakeholders
- All statutory compliances under Sections 230-232 made
- Accounting treatment certified by Karvy & Co, Chartered Accountants as compliant with Section 133
Penalties / Settlements / Directions
The Tribunal sanctioned the Scheme with specific directions:
Approval Conditions:
- Scheme sanctioned with Appointed Date as 01.10.2024
- Binding on all members, employees, creditors, and stakeholders
- No exemption from payment of stamp duty, taxes, or other charges
- All assets, properties, rights, and liabilities transferred without further act
Compliance Directions:
- Petitioner Companies to comply with all observations by statutory authorities
- Books of accounts and records preserved without disposal without Central Government permission
- Statutory compliance of all applicable laws ensured
- No absolution from statutory liability
- All legal proceedings to continue against Transferee Company
- Transferee Company liable for all pending tax demands
- Strict compliance with Accounting Standards under Section 133
- Revenue authority rights preserved for tax recovery
- Section 2(41) compliance if applicable
- Transferor Company dissolved without winding up
- Annual compliance statement filing requirement
- Rule 17(2) compliance within 30 days
Corrective Actions & Future Obligations
Petitioner Companies Undertakings:
- Record date to be fixed in mutual agreement between both companies
- No retrenchment of employees in service as on Appointed Date
- Differential fee payment for authorized capital consolidation after credit for fees already paid
- Full tax law compliance including any implications post-sanction
- Loans granted in compliance with Sections 185, 186, and 188
- Books preservation without prior Central Government permission
- Offences liability handling in accordance with law
Final Ruling & Enforcement
The Tribunal allowed CP (CAA) No.48/230/HDB/2025 with the following final order:
- Scheme of Amalgamation sanctioned with Appointed Date 01.10.2024
- Scheme binding on all stakeholders
- All regulatory observations to be complied with by Petitioner Companies
- Transferee Company bears all liabilities including tax demands
- Transferor Company dissolved without winding up
- Petitioner Companies to file certified copy with ROC in Form INC-28 within 30 days
- Liberty granted to any person to apply for necessary directions
- Petition disposed of accordingly
The order was signed by both Tribunal Members: Sd/- (Sanjay Puri), Member (Technical) and Sd/- (Rajeev Bhardwaj), Member (Judicial).