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    <title>1995 (7) TMI 228 - CEGAT, CALCUTTA</title>
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    <description>Delayed availment of higher notional credit under Rule 57B was treated as a factual issue, not a question of statutory interpretation. The challenge concerned only the timing of taking differential credit, while substantive eligibility to the credit was not in dispute. The time taken had to be judged on the facts and by a standard of reasonableness; on those facts, availing the credit after about three months did not raise any substantial question of law for reference. The controversy was therefore confined to factual reasonableness, leaving the Tribunal&#039;s allowance of credit undisturbed.</description>
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      <title>1995 (7) TMI 228 - CEGAT, CALCUTTA</title>
      <link>https://www.taxtmi.com/caselaws?id=88188</link>
      <description>Delayed availment of higher notional credit under Rule 57B was treated as a factual issue, not a question of statutory interpretation. The challenge concerned only the timing of taking differential credit, while substantive eligibility to the credit was not in dispute. The time taken had to be judged on the facts and by a standard of reasonableness; on those facts, availing the credit after about three months did not raise any substantial question of law for reference. The controversy was therefore confined to factual reasonableness, leaving the Tribunal&#039;s allowance of credit undisturbed.</description>
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