Validity of reassessment proceedings initiated u/s 147 to successor of business

Whether reassessment proceedings initiated u/s 147 to successor of business on account of omission and failure to disclose fully and truly all material facts necessary for determining the income chargeable to tax for these assessment years is valid? It was not the effective date but the appointed date which would determine and decide when Indofil Chemicals Ltd. had amalgamated with Modipon Ltd. Accordingly, the Assessing Officer held that the amalgamation of the two companies, i.e. petitioner-Modipon Ltd. and Indofil Chemicals Ltd., had taken place after 31st March, 1986 in view of Section 2(1...