Clubbing of clearances requires proved financial flowback or dominant control; shared utilities and workers alone are not enough.

Clubbing of clearances for exemption purposes requires evidence of financial flowback, common funding, or dominant control showing that separately run units are in substance one business concern. Mere shared infrastructure, utilities, or some common workers is insufficient without proof of an inextricable financial and managerial link. On the facts, the record did not establish investment of HUF funds in the Mohali units, financial flowback, or dummy-unit control by the alleged controller. The separate units were therefore not liable to be clubbed, and exemption treatment remained available as claimed.

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Issues: Whether the clearances of the Chandigarh and Mohali units were liable to be clubbed for the purpose of availing exemption under the relevant notification scheme.

Analysis: Clubbing of clearances requires material showing financial flowback, common funding, or such control and interconnection between the units as to justify treating them as one. Mere common use of infrastructure, utilities, or manpower is not enough by itself. On the facts found, the record did not establish investment of HUF funds in the Mohali units, any financial flowback between the units, or that the Mohali concerns were managed or controlled as dummy units by late Avdesh Garg. The presence of shared utilities and some common workers did not, without more, prove the requisite inextricable link or pecuniary interest.

Conclusion: The clubbing of clearances was not justified and the assessee was entitled to the exemption treatment as claimed.

Final Conclusion: The Revenue's challenge to the appellate order failed, and the disallowance of clubbing was upheld.

Ratio Decidendi: Clubbing of clearances cannot be sustained in the absence of proved financial flowback, common funding, or dominant control establishing that separate units are in substance one business concern.

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