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Issues: Whether the assessee was entitled to deduction under section 80J of the Income-tax Act, 1961 on the capital employed in the branch industrial undertaking as computed by the appellate authorities.
Analysis: The question was covered by the Supreme Court decision in Lohia Machines Ltd. v. Union of India, which governed the computation of capital for deduction under section 80J. Applying that authority, the capital base accepted by the Commissioner (Appeals) and the Tribunal could not be sustained.
Conclusion: The reference was answered in the negative and the assessee was held not entitled to the claimed computation of deduction under section 80J. The answer is in favour of the Revenue and against the assessee.