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<h1>Proof of Shells Use Required for Tax Exemption</h1> The Supreme Court of India held that the appellants must prove to the Assistant Commissioner the use of shells and hulls in their factory to qualify for ... Shells and hulls The Supreme Court of India ruled that the appellants must satisfy the Assistant Commissioner regarding the use of shells and hulls in their factory to qualify for exemption under Notification No. 118 of 1975. The civil appeal is disposed of with no order as to costs.