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1985 (12) TMI 83 - ITAT BOMBAY-CExtract: .......essee as well as the department have treated the project report as capital asset and as such, we have to decide this appeal on the basis that the said project report was a capital asset. The alternate submission does not arise out of the order of the AAC and there is no specific ground in the memo of appeal. 8. In the result, the appeal is allowed.
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