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(i) an assessment itself is one thing and the reopening of an assess-'ment already made for short levy is another; and

(ii) once the liability accrued and put in issue in an appropriate proceeding, subsequent changes in the constitution of the assessee should have little effect on 4he validity or legality of such proceeding. Were it not so, every proceeding that already commenced may be defeated by the simple device of a change in the constitution of the assessee;

(g) in any event, the effect, if at all, of the various changes in the constitution of the assessee right from the time when the alleged liability accrued on the validity and legality of the adjudication would depend to a large extent on the covenants inter se relating to the devolution of rights and liabilities upon the successor in interest each time a change in constitution occurs. Suffice it to observe from para 6 of the deed of dissolution that every liability of the short lived partnership, including Central Excise, whether existing or contingent, had devolved on the present applicant. All the quandom partners had converted their shares in the partnership into shareholdings in the applicant and one of them is a director of the applicant;