In the result, both the appeals are partly allowed
Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury
72A, like some other provisions distinctly dealing with the effects of amalgamation, exclusively applies to accumulated losses and unabsorbed depreciation of the amalgamating company in relation to the income under the head “Profit and gains of business or profession”. It is not a panacea for all the tax related issues of amalgamation, so as to have application insofar