Compliance with conditions u/s 72A is to be tested in relation to each amalgamating company

During the AY 2004-05, BTPU and BSPPL amalgamated with the taxpayer. The taxpayer claimed set-off of losses of BTPU under section 72A. The AO disallowed the set-off of loss brought forward on the basis that the taxpayer failed to: Hold three-fourth of the book value of fixed assets of amalgamating company for a continuous period of five years; Achieve the production of 50 percent of the installed capacity of the amalgamating company as per Rule 9C within a period of three years and nine months; and Furnish the certificate of particulars of production in the prescribed form under Rule 9C. A...