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1994 (11) TMI 260 - CEGAT , BOMBAYExtract: .......en filed with the Asstt. Collector. Since this is a factual appreciation of the position, denial of modvat credit only on this ground, amounts to denial of substantive benefit. We feel that the reference is not called for, since it is a purely appreciation of the factual position as discussed above. We, therefore, dismiss the reference application.
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