Case Details
Case Name: CP (CAA) 50/Chd/Hry of 2025 (2nd Motion)
Parties: Megashop Retail Private Limited (Petitioner Company No. 1/Demerged Company) and V-Bazaar Retail Private Limited (Petitioner Company No. 2/Resulting Company)
Court/Authority: National Company Law Tribunal Chandigarh Bench (Court-II)
Order Date: 22 May 2026
Appointed Date for Scheme: 01 April 2025
Period of Proceedings: First Motion Application filed as CA(CAA) No. 14/Chd/Hry/2025, approved on 08 August 2025
Parties Involved
Petitioners:
- Megashop Retail Private Limited (CIN: U52500HR2022PTC127817, PAN: AAQCM1105R)
- V-Bazaar Retail Private Limited (CIN: U52100HR2016PTC126327, PAN: AAFCV3666D)
Regulatory Authorities:
- Regional Director (RD) and Registrar of Companies (ROC), Chandigarh
- Income Tax Department
- Official Liquidator
Legal Representatives:
- Mr. Nahush Jain, Advocate for Petitioner Companies
- Dr. Kishorkumar Devarwade, Assistant Director for ROC Chandigarh/RD
- Mr. Edward Augustine George, Advocate for Official Liquidator
- Mr. Varun Issar, Sr. Standing Counsel for Income Tax Department
Issues / Allegations / Violations
The petition was filed under Sections 230 & 232 of the Companies Act, 2013 for sanction of a Scheme of Arrangement for Demerger between Megashop Retail and V-Bazaar Retail. The regulatory authorities raised specific concerns:
Income Tax Department Observations for Megashop Retail (Company 1):
- Requested direction that all Income Tax Act compliances be made by the amalgamated entity
- Noted Megashop had carry forward losses of ₹6,32,78,875/- for AY 2025-26 intended to be set off against V-Bazaar income, which was "adverse to the interest of revenue"
- Requested protection of revenue loss by taking undertaking from resultant company
- Noted outstanding demand of ₹13,14,31,506/- and carry forward losses of ₹13,02,93,541/-
Regional Director Observations for V-Bazaar (Company 2):
- Noted statutory dues from Income Tax and GST authorities requiring clarification
Findings & Observations
The Tribunal found:
- The Scheme appears prima facie compliant with all requirements under the Companies Act, 2013
- Petitioner companies provided adequate clarifications to statutory authorities' observations
- The proposed Scheme is bona fide and in the interest of shareholders and creditors
- All requisite statutory compliance has been fulfilled
- Meetings of secured and unsecured creditors of both companies were convened on 09 October 2025 and approved the Scheme with requisite majority
Penalties / Settlements / Directions
No penalties imposed. The Tribunal sanctioned the Scheme with specific directions:
Tax-Related Safeguards:
- Income Tax Department free to examine tax payable resulting from the scheme
- If scheme results in tax avoidance or non-compliance with Income Tax Act, department may initiate appropriate action
- Scheme sanction shall not adversely affect rights of Income Tax Department
- Treatment of carry forward losses subject to Section 72A and applicable provisions of Income Tax Act, 1961
Operational Directions:
- All property, rights and powers of demerged undertaking transferred to V-Bazaar Retail
- All liabilities and duties of demerged business transferred to V-Bazaar Retail
- All contracts pertaining to demerged undertaking transferred to V-Bazaar Retail
- All employees of demerged undertaking transferred to V-Bazaar without service interruption
- All pending proceedings against demerged business to continue against V-Bazaar
- V-Bazaar to allot shares to existing Megashop members as per Scheme
Corrective Actions & Future Obligations
Filing Requirements:
- Petitioner companies to furnish self-certified copy of approved Scheme and Schedule of Assets to Designated Registrar
- V-Bazaar to file certified copy of Order with Scheme and Schedule of Assets with ROC in e-form INC-28 within 30 days
- V-Bazaar to lodge copy of Order and Scheme with Superintendent of Stamps for stamp duty adjudication within 60 days
Compliance Undertakings:
- Megashop undertook that treatment of carry forward losses subject to Section 72A of Income Tax Act
- Both companies undertook that Scheme does not extinguish, reduce or adversely affect rights of Income Tax Department
- Companies committed to discharge all statutory liabilities as they crystallize
Final Ruling & Enforcement
The Tribunal:
- Sanctioned the Scheme of Arrangement between Megashop Retail and V-Bazaar Retail
- Declared the Scheme binding on both companies, their shareholders and creditors
- Approved the Appointed Date of 01 April 2025 for the Scheme
- Disposed of the Company Petition (CAA) No. 50/Chd/Hry of 2025
- Directed all regulatory authorities to act on authenticated copy of the Order
- Preserved right of aggrieved persons to apply for necessary directions