1. The four appeals arise from the very same period spanning 27 months, due to the peculiar facts and circumstances of two companies having been amalgamated.

2. We would first notice the background facts arising in the above cases and would deal with the documents as produced in ITA No.108/2002. There were two Companies incorporated under the English Companies Act; M/s.Harrisons & Crossfield (I) Ltd. (HCL) and M/s.Malayalam Plantations (I) Ltd. (MPL). HCL was amalgamated with MPL w.e.f. 01/01/1983. The scheme of amalgamation, which had the approval of this Court, is produced as Annexure - D. While HCL was following the calendar year for the purpose of income tax assessment, MPL was following the financial year. Hence, when the two Companies got amalgamated, MPL applied for change of previous year relevant to the assessment year by Annexure - E and the change was permitted by Annexure - F. The application is seen filed by HCL itself. The 18 months comprised between 01/01/1983 and 30/06/1984 was, by Annexure - F, permitted to be the previous year of the assessment year 1985-86, since, 30/06/1984 was the date on which MPL closed its accounts. When the assessment was made for the asse