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The assessee is a company whose industrial undertaking was nationalised. The Act under which it was taken over provided for compensation in a limited sum to be distributed (sic-among) the classes of persons in the order of priority provided in the Schedule to the Act. The arrears of tax for the years prior to the date of nationalisation that is in 1986 is not an item for which first priority is given. That liability is not taken over by the Government or by the corporation. The undertaking of this company was subsequently transferred by the Government to the Pondicherry Textiles Corporation. This court in the case of Pondicherry Textiles Corporation v. Union of India (1999) 239 ITR 457 (Mad) after considering the provisions of the Anglo-French Textiles Limited (Acquisition and Transfer of Textiles Undertaking) Act, 1986, held that the Pondicherry Textiles, Corporation is not the successor of Anglo French Textiles, although the entire undertaking was transferred by the Government to the said Pondicherry Textiles Corporation as none of the liabilities of that company were taken over. The application to substitute the said Pondicherry Textiles Corporation as the respondent is, therefore, dismissed.