Amalgamation/merger of aprvd grty & superannuation trust

Hello !!! Before I come to the queries, I would like to bring the following facts on the board:

1. We had created four different TRUSTs for employees gratuity & superannuation benefits in our company in four different states.

2. Basically, these trusts belongs to the former companies and post amalgamtion with current company, being regulated by present company.

3. All these trusts are having similar rules & schemes and duly approved from ITOs of their jurisdictions. 

4. For administrative convienience, we have decided to merger/amalgamte these schemes/trusts with one trust/scheme and accordingly floated all required documents, deeds, resolutions etc with the help of our insurer e.g. LIC.

5. We initiated the approval of Commissioner of ITO, ABC of the jurisdiction of main trust in which all other trusts are going to be merged.

6. The respective ITO, ABC has recommended to Commissioner for approval of the merger of all schemes.

7. Commissioner upon receiving of recommendation of ITO, ABC for approval of merger of schemes, has put our application on hold and asked us to get the approval of ITOs of former schemes which are going to be merged.

8. We followed the lines and initiated the application of merger approval to ITOs of XYZ & CBA e.g. jurisdiction of former trusts in Nov 12 and submitted the acknowledgment copies to the ITO, ABC.

9. But Commisisoner has refused to procced further till the approval of ITOs of former trusts.

10. Approval of ITOs of former trusts are still awaited.  

In the view of above, We want to know our position that:

1. Whether we can go for merger of schemes without waiting for formal approval of ITO, Pune or Delhi or Bangalore, based upon merely submission of application for approval of merger to respective ITOs?

2. Whether submission of application to ITOs can be deemed to be approved after a sufficient time. In our case, it is now three months?

3. Since ITO, ABC has not rejected and kept our application on hold till the approval of other ITOs, same can can be deemed to be approved?   Please guide ?