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Mahaamba Investments Ltd. vs Idi Limited on 31 January, 2001

In the case of Mahaamba Investments Ltd. (supra), the question came up before the Mumbai High Court on objection raised by the office that only transferor company seeking its amalgamation with another company has submitted petition under Section 391-394 of the Companies Act, 1956 but no petition has been filed by the transferee company seeking sanction of High Court for amalgamation of the other company in transferee company. The Mumbai High Court considered the facts of the case and found that the transferee is a holding company of the transferor company which was 7 SB Company Application No.3/2009 ESL India Limited. vs. Secure Meters Limited 100% subsidiary company of the transferee company. Clause 10 of the proposed scheme of amalgamation submitted by the transferor company provided that since the entire share capital of the transferor is held by the transferee and upon the scheme becoming final and effective, the said share capital of the transferor will stand automatically cancelled and no shares will be allotted of the transferee company to the shareholders of the transferor company and that will be because the transferee company holds 100% of the share capital of the transferor company.

Bank Of India Ltd. vs Ahmedabad Manufacturing & Calico ... on 1 September, 1971

Similar question came up for consideration of Mumbai High Court in the case of Bank of India Ltd. vs. Ahmedabad Mfg. & Calico Printing Co. Ltd. (1972) 42 Comp Cas 211 in which, considering the judgment of Delhi High Court delivered in the case of Sharat Hardware Industries (P.) Ltd. In re. (1978) 48 Comp Cas 23, the Court held that, "if a scheme by way of transfer of undertaking does not affect the rights of the members or creditors of the transferee-company, as between themselves and the company, or does not involve a reorganisation of the share capital of the transferee-company, no application by the transferee- company under section 391 or section 394 would be 8 SB Company Application No.3/2009 ESL India Limited. vs. Secure Meters Limited necessary." After considering the above judgments, the Mumbai High Court in the case of Mahaamba Investments held that where no new shares are sought to be issued to the members of the transferor company by the transferee company, the scheme will not affect the members of transferee company. The creditors of the transferee-company are not likely to be affected by the scheme in view of the financial position of the transferee-company. In view of the above, the Mumbai High Court held that filing of separate petition by the transferee company is not necessary.
Bombay High Court Cites 19 - Cited by 31 - Full Document
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