( 1 ) SECTION 72a of the Income Tax Act, 1961 (hereinafter called the Act) was inserted by the Finance (No. 2) Act, 1977 with effect from April 1, 1978. By this section, a provision is made to enable an amalgamated company to carry forward and set off of accumulated loss and unabsorbed depreciation allowance in certain in cases of amalgamation of companies on fulfilment of conditions mentioned in sub-section (1) of Section 72a and the Central Government s satisfaction in respect thereof, namely that the amalgamating company was not immediately before such amalgamation, financially viable by reason of its liabilities, losses and other relevant factors and that the amalgamation was in the public interest. The satisfaction of the Central Government is to be arrived at after considering the recommendations of the Specified Authority being such authority that the Central Government, may, by notification in the Official Gazette specify for the purposes of Section 72a. The effect of such declaration is, that notwithstanding anything contained in any other provision of the Act, the accumulated loss and the unabsorbed depreciation of the amalgamating company, was deemed to