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The Bombay High Court ruled that the sum of Rs. 12,10,279 from the sale of 'import entitlements' was not exempt under section 10(3) of the Income-tax Act, 1961, and was not eligible for rebate under section 2(4)(a)(i) and (ii) of the Finance (No. 2) Act of 1967. The judgment favored the Revenue based on precedent.
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