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    <title>1982 (3) TMI 231 - GUJARAT HIGH COURT</title>
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    <description>Rule 42-A of the Gujarat Sales Tax Rules was construed purposively as an incentive for certified new industries, so the set-off for tax paid on raw materials used in manufacture was not confined to goods sold within the State. The ordinary statutory meaning of &quot;sale&quot; yielded to the scheme, object and structure of the rule, which contained no express situs restriction. On that basis, full set-off remained available even where finished goods were sold outside the State, and the purchase tax levy and consequential penalty were unsustainable once the full set-off applied.</description>
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    <pubDate>Fri, 05 Mar 1982 00:00:00 +0530</pubDate>
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      <title>1982 (3) TMI 231 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=153269</link>
      <description>Rule 42-A of the Gujarat Sales Tax Rules was construed purposively as an incentive for certified new industries, so the set-off for tax paid on raw materials used in manufacture was not confined to goods sold within the State. The ordinary statutory meaning of &quot;sale&quot; yielded to the scheme, object and structure of the rule, which contained no express situs restriction. On that basis, full set-off remained available even where finished goods were sold outside the State, and the purchase tax levy and consequential penalty were unsustainable once the full set-off applied.</description>
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      <pubDate>Fri, 05 Mar 1982 00:00:00 +0530</pubDate>
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