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2015 (12) TMI 1326 - ITAT KOLKATA

2015 (12) TMI 1326 - ITAT KOLKATA - TMI - Disallowance u/s 14A - Held that:- We find from the facts of the instant case that the Learned AO has not examined the accounts of the assessee and there is no satisfaction recorded by the Learned AO about the correctness of the claim of the assessee and without the same, he invoked Rule 8D of IT Rules. While rejecting the claim of assessee with regard to expenditure in relation to exempt income, the Learned AO has to indicate cogent reasons for the same .....

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ions of the Act and not for book profits u/s 115JB of the Act. Unless an item is debited in the profit and loss account, the same cannot be the subject matter of addition to book profits under clause (f) of Explanation to section 115JB of the Act. The disallowance made u/s 14A of the Act read with Rule 8D is only artificial disallowance and obviously the same is not debited in the profit and loss account and the same cannot be imported into clause (f) of Explanation to Section 115JB of the Act. .....

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n on this account was made. This goes to prove that the revenue had already accepted to the contentions of the assessee on the impugned issue and satisfied that the cess collected from customers have been duly remitted in the succeeding year in accordance with the provisions of The West Bengal Rural Employment and Production Act, 1976 and The West Bengal Primary Education Act, 1973 and was also satisfied with the manner of treatment of the same by the assessee for tax purposes. Having done so, t .....

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he case of CIT vs G.S.Atwal & Co [ 2001 (2) TMI 32 - CALCUTTA High Court ] if the assessee owns the machinery for which investment allowance is claimed, and such machinery is used for production then the section applies, it does not matter if the use for production is made by the lessee or only in one industrial part of the assessee’s business undertaking. Accordingly, the transport business of the assessee does not tilt the question one way or the other - Decided in favour of assessee - I.T.A N .....

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ed AO u/s 143(3) of the Income Tax Act, 1961 (hereinafter referred to as the Act ). ITA No. 1146 / 2012 - Assessee Appeal 2. The first issue to be decided in this appeal is as to whether the disallowance u/s 14A of the Act could be made in the facts and circumstances of the case. 2.1. The brief facts of this issue is that the assessee has earned dividend income amounting to ₹ 33,61,665/- during the assessment year under review. The breakup of the same is as below:- Dividend from CESC Ltd - .....

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g value of current investment (3,30,924) - 92,08,87,174 38,46,97,320 2.2. Out of the aforesaid investments, the assessee had earned dividend only from CESC Ltd and from UTI Mutual fund which was purchased and sold during the year. The assessee voluntarily disallowed a sum of ₹ 29,760/- u/s 14A of the Act in the return of income. The Learned AO resorted to ignore this disallowance without adducing any reason and without recording any satisfaction in terms of section 14A read with Rule 8D(1) .....

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sessee company offered ₹ 29,760/- as disallowance u/s. 14A. The submission of the assessee company is not acceptable. The disallowance u/s. 14A read with rule 8D is calculated under:- Opening Value of Investments ₹ 38,46,97,320/- Closing Value of Investments Rs.92,08,87,174/- Total Rs.130,55,84,494/- Average Value ₹ 62,27,92,247/-……[B] Opening Value of assets Rs.149,88,20,757/- Closing Value of assets Rs.121,75,81,854/- Total Rs.271,64,02,611/- Average Value of as .....

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direct relation between the expenditure incurred by the assessee on investment and dividend from other companies received by assessee. He further observed that in some years the dividend may be more than expenditure and in some years it may be less as enough dividend may not be paid by other companies due to lesser profits. He also observed that the companies in which assessee has made investments are almost from the same group of management and the payment of dividend is dependent on so many fa .....

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he common kitty. There may not be any immediate correlation between the funds taken for loan and investments in the shares. 2.3.3. He observed that there is no presumption provided in the Act that investments were made out of own funds of the assessee if the assessee has interest free loans, his own capital as share capital, reserves and surpluses and interest bearing loans and is earning exempt and taxable income. 2.3.4. The Learned CITA relied on the following decisions of Jurisdictional High .....

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proceedings. Thus, the approach of the Assessing officer to work out the prorata interest expenditure as relatable to earning of dividend was quite in conformity with the provisions of Section 14A of the Act and we do not find any reason to disturb the said order in the light of the amended provisions of Section 14A of the Act. We, therefore, find no substance in the aforesaid contention of Mr. Khaitan that the Revenue cannot get the benefit of Section 14A of the Act and consequently, dismiss t .....

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y loan. If those shares were purchased from the amount taken in loan, even for instance, five or ten years ago, it is for the assessee to show by the production of documentary evidence that such loaned amount had already been paid back and for the relevant assessment year, no interest is payable by the assessee for acquiring those old shares. In the absence of any such materials placed by the assessee, in our opinion, the authorities below rightly held that proportionate amount should be disallo .....

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, the expenditure incurred for earning the income is deductible notwithstanding the fact that no such income has been earned. It has been held as under:- 3. We have considered the facts of the case and submissions made before us. Section 14A(1) speaks about disallowance of expenditure incurred in relation to income which does not form part of the total income. The first argument of the learned counsel is that only those investments can be taken into account for the purpose of Rule 8D from which .....

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ose of earning the income. Thus, where investment has been made in shares, which did not yield and dividend in the year under consideration, the expenditure incurred for earning the income is deductible notwithstanding the fact that no such income has been earned. We are of the view that ratio of these cases will apply mutatis mutandis under sec. 14A of the Act also while ascertaining the expenditure incurred for earning tax-free income from investment. Cheminvest Ltd vs ITO reported in (2009) 1 .....

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irmative then that expenditure cannot be allowed irrespective of the fact that it was allowable under different provisions of the Act where an different phraseology is used in allowing that expenditure as the focus has to on disallowance within parameters of section 14A, an overriding provision over allowance provisions. It would result in disallowance even of no income has resulted or made or earned by the assessee in the year under consideration. We also make it clear that the disallowance has .....

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on of the Assessing Officer in invoking Rule 8D to the Income-tax Rules, 1962 ( the Rules ) for the purpose of arriving at the amount disallowable u/s. 14A of the Income-tax Act, 1961 ( the Act .) 1(b) That the learned CIT(Appeals) erred in confirming the action of the Assessing Officer in disallowing an aggregate further amount of INR 44,91,468/- u/s. 14A of the Act by applying Rule 8D to the Income-tax Rules, 1962. 1(c) That the learned CIT(Appeals) erred in observing that the Assessing Office .....

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dmittedly utilized only for the purpose of business and not for making any investments by the assessee. No interest was debited in respect of this unsecured loan of ₹ 7 crores. He argued that the Learned AO made this disallowance as if the same is automatically to be applied from Asst Year 2008-09 which is quite evident from the assessment order which is reproduced hereinabove. He argued that the assessee has got sufficient own funds to make these investments and borrowed funds were admitt .....

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Jhunjhunwala in G.A.No. 2990 of 2013 in ITAT No. 157 of 2013 dated 8.1.2014 rendered by Calcutta High Court • CIT vs R.E.I. Agro Ltd in GA 3022 of 2013 in ITAT 161 of 2013 dated 23.12.2013 rendered by Calcutta High Court 2.4.2. Alternatively, he argued that the investments that did not yield any dividend income during the year needs to be excluded for the purpose of disallowance u/s 14A of the Act. He stated that the dividend was received only from investment with CESC Ltd which is outstand .....

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ous case laws relied upon by both the sides. We find from the facts of the instant case that the Learned AO has not examined the accounts of the assessee and there is no satisfaction recorded by the Learned AO about the correctness of the claim of the assessee and without the same , he invoked Rule 8D of IT Rules. While rejecting the claim of assessee with regard to expenditure in relation to exempt income, the Learned AO has to indicate cogent reasons for the same. We find that the Learned AO h .....

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exempted income, the AO has to indicate cogent reasons for the same. From the facts of the present case, it is noticed that the AO has not considered the claim of the assessee and straight away embarked upon computing disallowance under Rule 8D of the Rules on presuming the average value of investment at ½% of the total value. In view of the above and respectfully following the coordinate bench decision in the case of J.K. Investors (Bombay) Ltd., supra, we uphold the order of CIT (A)&qu .....

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nt of law has been raised. Therefore, this appeal is dismissed . The aforesaid two decisions of the Jurisdictional High Court are binding on this tribunal and hence the case laws addressed by the Learned CITA in his order are not considered in this order. We also find that one of the decisions relied upon by the Learned CITA is that of Jurisdictional High Court in the case of Dhanuka & Sons (supra)). We find that the facts in the case of Dhanuka & Sons are totally different from the fact .....

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ould be made in the facts of the instant case. 2.6.1. We also find that the assessee has got sufficient own funds to make these investments and the Learned AO had not brought any nexus between the borrowed funds vis a vis the investments made by the assessee. Without doing the same, he cannot directly presume that the investments were made out of borrowed funds. If the action of the Learned AO and Learned CITA are to be upheld, then no assessee could make any investments when there is a interest .....

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are more than the investments made by the assessee, then it has to be presumed that the investments were made out of own funds and not out of borrowed funds. Hence we hold that no disallowance u/s 14A of the Act could be made in these circumstances. 2.6.2. We also find that the investments made in subsidiaries by the assessee are only strategic investments and were made with a primary object to acquire controlling interest in group concerns and not for earning any income out of that investment. .....

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e basic intention behind introduction of section 14A itself is only to disallow the expenditure incurred for earning an income which does not form part of the total income. When there is no income which is claimed as exempt, then there is no scope for provisions of section 14A to operate. In the instant case, the assessee derived dividend income which is exempt only from CESC Ltd and from UTI Mutual Fund (which was purchased and sold during the year itself). Hence even assuming if disallowance i .....

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IT vs Shivam Motors in ITA No. 88 of 2014 dated 5.5.2014 rendered by Allahabad High Court • CIT vs Lakhani Marketing in ITA No. 970 of 2008 rendered by Punjab & Haryana High Court • CIT vs Delite Enterprises in ITA No. 110 of 2009 rendered by Bombay High Court The decision of special bench of Tribunal in the case of Cheminvest Ltd vs CIT reported in 121 ITD 318 had held that disallowance u/s 14A could be made even in an year in which no exempt income was earned or received by the a .....

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nsidered for disallowance u/s 14A of the Act. Respectfully following the aforesaid judicial precedents, we have no hesitation in directing the Learned AO to delete the addition made u/s 14A of the Act. Accordingly, the ground nos. 1 (a) to (c ) raised by the assessee are allowed. 3. The next ground to be decided in this appeal is that whether the disallowance u/s 14A of the Act could be made to the book profits computed u/s 115JB of the Act. The assessee has raised the following ground before us .....

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Act. The Learned DR argued that the disallowance u/s 14A of the Act would automatically fall in clause (f) of Explanation to section 115JB of the Act and hence needs to be added back for computation of book profits u/s 115JB of the Act. 3.2. We have heard the rival submissions. We find lot of force in the argument of the Learned AR that computation of disallowance under Rule 8D can be used only for computation of income under normal provisions of the Act and not for book profits u/s 115JB of th .....

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f the Act would operate in the facts and circumstances of the case. Accordingly, the ground no. 1(d) raised by the assessee is allowed. 4. The next ground to be decided in this appeal is as to whether provision for leave encashment which has been debited in the profit and loss account based on actuarial valuation to the tune of ₹ 2,00,576/- would come under the ambit of provisions of section 43B of the Act. 4.1. The brief facts of this issue is that assessee debited a sum of ₹ 2,00,5 .....

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nces of the case, the learned CIT(Appeals) erred in confirming the action of the Assessing Officer in disallowing a sum of INR 2,00,576 representing amount debited to its Profit & loss A/c by the appellant towards provision for leave encashment based on actuarial valuation, by invoking the provisions of section 43B of the Act. . 4.2. The Learned AR relied on the decision of the Jurisdictional High Court in the case of Exide Industries Ltd vs Union of India reported in 292 ITR 470 (Cal) where .....

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se to this, the Learned DR vehemently supported the order of the lower authorities. 4.3. We have heard the rival submissions and we find case laws quoted by the Learned AR. We find that it is relevant to get into the operative portion of the decision of the Calcutta High Court in the case of Exide Industries Ltd vs Union of India reported in 292 ITR 470 . It was held as below:- 11. In this regard the observation of the apex Court in the case of Bharat Earth Movers (supra) is quoted below: The la .....

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be discharged at a future date. It does not make any difference if the future date on which the liability shall have to be discharged is not certain.... Applying the abovesaid settled principles to the facts of the case at hand we are satisfied that the provision made by the appellant company for meeting the liability incurred by it under the leave encashment scheme proportionate with the entitlement earned by employees of the company, inclusive of the officers and the staff, subject to the cei .....

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he revenue had preferred Special Leave Petition (SLP) before the Hon ble Supreme Court against the judgement of Hon ble Calcutta High Court. The Hon ble Apex Court in SLP proceedings in CC 12060 / 2008 dated 8.9.2008 had held as under:- The petition was called on for hearing today. Upon hearing counsel the court made the following Order. Issue Notice. In the meantime, there shall be stay of the impugned judgement, until further orders. Later the Hon ble Supreme Court in CC 22889 / 2008 dated 8.5 .....

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ed. We further make it clear that the assessee would, during the pendency of this Civil Appeal , pay tax as if Section 43B(f) is on the statute book but at the same time it would be entitled to make a claim in its returns. In the aforesaid circumstances, we deem it fit and appropriate , in the interest of justice and fair play, to set aside this issue to the file of the Learned AO to pass orders based on the outcome of the main appeal on merits by the Hon ble Supreme Court as stated supra. Accor .....

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of coal. The mines of the assessee are located within the State of West Bengal. The Government of West Bengal levies and collects two cess namely Rural Employment Cess ( RE Cess ) and Primary Education Cess ( PE Cess ) from enterprises engaged in the mining and extraction of coal within the State of West Bengal. The assessee is bound to pay Rural Employment Cess and Primary Education Cess on production of coal of each year payable in the succeeding year. The said cess is collected by the assess .....

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n this regard was also mentioned in the notes to tax audit report stating the reasons for not statutorily accruing this receipt in the asst year under appeal. The Learned AO however observed that these receipts in the form of cess collected out of sale invoices are nothing but trading receipts and hence if the same are not paid within the due date of filing the return of income, then the same are liable for disallowance u/s 43B of the Act by placing reliance on the decision of the Hon ble Apex C .....

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, 1976 , the said Act does not override the Income Tax Act and hence the cess collected from customers would become trading receipts as per the Supreme Court decision relied upon supra. While doing so, the Learned AO did not give deduction for cess paid from 1st April to the due date of filing the return of income u/s 139(1) of the Act even as per his own analogy in applying the provisions of section 43B of the Act. Aggrieved, the assessee is in appeal before us on the following grounds:- 3(a) T .....

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to appreciate that both RE Cess and PE Cess having not statutorily accured during the financial year under consideration, are outside the ambit of section 43B of the Act. 3(d) That the learned CIT(Appeals) erred in observing that the RE Cess and PE Cess aggregating to ₹ 38,05,12,458/- collected are nothing but trading receipts of the appellant and taxable in the previous year under consideration. 3(e) That without prejudice to the above, having disallowed the RE Cess and PE Cess u/s. 43B o .....

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76 and The West Bengal Primary Education Act, 1973. He took us to the relevant provisions of the said Act in this regard. He argued that the cess collected remains only as a liability and it does not become payable under the relevant law and hence the provisions of section 43B of the Act would not come into operation. In response to this, the Learned DR argued that the cess is collected by the assessee from the sale invoice and hence takes the character of a trading receipt and accordingly relie .....

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ing the asst year under appeal. In other words, the cess does not become payable in the asst year under appeal. Now let us go into the provisions of section 43B of the Act which is reproduced herein below:- [ Certain deductions to be only on actual payment] 43B Notwithstanding anything contained in any other provision of this Act, a deduction other- wise allowable under this Act in respect of- [(a)] any sum payable by the assessee by way of tax, duty, cess or fee, by whatever name called, under .....

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the assessee on or before the due date applicable in his case for furnishing the return of income under sub-section (1) of section 139 in respect of the previous year in which the liability to pay such sum was incurred as aforesaid and the evidence of such payment is furnished by the assessee along with such return. [Explanation 2.- For the purposes of clause (a), as in force at all material times," any sum payable" means a sum for which the assessee incurred liability in the previous .....

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gal Primary Education Act, 1973. Hence in these facts and circumstances, the version of the Learned CITA that the other acts shall not override the provisions of Income Tax Act is not at all relevant. We hold that the cess collected from customers out of sale price in the facts and cirumstances of the instant case cannot be construed as trading receipts chargeable to tax as the same are collected in advance for payment to the exchequer in the succeeding year under the relevant Act. Hence we cann .....

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ind that Asst Year 2003-04 was the first year of operation for the assessee wherein similar addition made by the Learned AO was deleted by the Learned CITA and the revenue had not preferred any appeal against the same before this tribunal. Similarly in Asst Year 2006-07, no disallowance under this head was made by the Learned AO eventhough the assessment was completed u/s 143(3) of the Act. These are the only two scrutiny assessments done by the Learned AO on the assessee prior to the assessment .....

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roceedings. Again, each assessment year being a unit, what is decided in one year may not apply in the following year but where a fundamental aspect permeating through the different assessment years has been found as a fact one way or the other and the parties have allowed that position to be sustained by not challenging the order, it would not be at all appropriate to allow the position to be changed in a subsequent year. We find that the assessee has been consistently following this practice o .....

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d reported in 358 ITR 295 (SC) wherein their Lordships had held as follows:- Secondly as noted by the tribunal, a consistent view has been taken in favour of the assesssee on the questions raised, starting with the assessment year 1992-93 , that the benefits under the advance licences or under the duty entitlement pass book do not represent the real income of the assessee. Consequently, there is no reason for us to take a different view unless there are very convincing reasons, none of which hav .....

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oney in purusing litigation for the sake of it. 5.3.3. We are also reminded of the observations of Hon ble Justice P.N. Bhagwati while rendering the judgement in the case of Distributors (Baroda) P Ltd vs Union of India & Ors reported in 155 ITR 120 (SC) - larger bench decision as below:- To perpetuate an error is no heroism. To rectify the same is the compulsion of judicial conscience. In the facts of the instant case, the assessee had commenced its operations from Asst Year 2003-04 and in .....

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rdance with the provisions of The West Bengal Rural Employment and Production Act, 1976 and The West Bengal Primary Education Act, 1973 and was also satisfied with the manner of treatment of the same by the assessee for tax purposes. Having done so, there is no good reason for the revenue to shift its stand in the assessment year under appeal. To this extent, the decisions of the Hon ble Apex Court and the observation made by the apex court (supra) are relevant to the facts of the instant case. .....

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assessee is entitled to additional depreciation of ₹ 75,400/- on the basis that coal mining is production of coal or not, in the facts and circumstances of the case. 6.1. The brief facts of this issue is that the assessee claimed additional depreciation of ₹ 75,400/- on survey instrument which was acquired on 8.12.2007. According to the Learned AO , the assessee is enaged in mining of coal and not in manufacturing or producing any thing or article. Hence he felt that the assessee is .....

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400/- should be allowed on the basis that coal mining is production of cost. 6.2. The Learned AR relied on the order of the Learned CITA. In response to this, the Learned DR argued that coal mining does not bring into effect any new product as even after mining, the end product is only coal and hence no transformation happens in the said process. He further placed reliance on the definition of manufacture in section 2(29BA) of the Act which defines as follows:- [29BA) manufacture with its gramma .....

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l mining could be construed as production of coal and if so, the assessee is entitled for additional depreciation. We find that this issue is squarely covered by the decision of the Jurisdictional High Court in the case of CIT vs G.S.Atwal & Co reported in 254 ITR 592 (Cal) wherein it was held as below:- 13. Following an old and long standing decision given by Chakravarti C.J in 1959, which was later approved by the Supreme Court, the Division Bench opined that the winning of coal is no doub .....

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is actually used by its lessee for the purpose of production. Going on the language of sub-sections (1) and (2) of the said section, the Supreme Court found, on an accurate assessment of the language ( we say this with the greatest respect), that the language does not disentitle the financier from investment allowance in the above circumstances. 14. Even considering the later Supreme Court decision given by Mr. Agarwalla, we are still of the opinion that the view taken by our Division Bench as t .....

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tion 33B of the Act. Explanation, mining activity would bring the assessee within the definition of an industrial undertaking. But we need not import the definition of another section to the present one, although ordinarily the definition given in one section in an Act can be used for the purposes of another section unless the context indicates otherwise. 16. so far as the assessee is concerned, an undertaking it certainly is. We have found no facts from which we can opine that the assessee is n .....

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