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    <title>1962 (2) TMI 97 - MADRAS HIGH COURT</title>
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    <description>Relief under section 15C is confined to profits or gains directly derived from the industrial undertaking itself, and the provision must be strictly construed. Income arising from a source distinct from the undertaking cannot qualify merely because it is commercially connected with the manufacturing business. On that principle, profits from the purchase and sale of spare parts not manufactured in India were treated as a separate trading activity, and the assessee&#039;s contractual obligation to import and sell those parts did not bring the income within the industrial undertaking. The exemption was therefore unavailable, and the issue was decided against the assessee and in favour of the Revenue.</description>
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    <pubDate>Tue, 20 Feb 1962 00:00:00 +0530</pubDate>
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      <title>1962 (2) TMI 97 - MADRAS HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=188497</link>
      <description>Relief under section 15C is confined to profits or gains directly derived from the industrial undertaking itself, and the provision must be strictly construed. Income arising from a source distinct from the undertaking cannot qualify merely because it is commercially connected with the manufacturing business. On that principle, profits from the purchase and sale of spare parts not manufactured in India were treated as a separate trading activity, and the assessee&#039;s contractual obligation to import and sell those parts did not bring the income within the industrial undertaking. The exemption was therefore unavailable, and the issue was decided against the assessee and in favour of the Revenue.</description>
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      <pubDate>Tue, 20 Feb 1962 00:00:00 +0530</pubDate>
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