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    <title>1964 (2) TMI 90 - CALCUTTA HIGH COURT</title>
    <link>https://www.taxtmi.com/caselaws?id=188592</link>
    <description>Profits exemption under section 15C was confined strictly to income derived from the industrial undertaking itself. The court held that the manufacture and sale of industrial gases and the separate commercial sale of equipment and allied goods constituted distinct undertakings because each could operate independently of the other. Applying a strict construction of section 15C, it further held that profits from the non-industrial business were not exempt merely because they were incidental or associated with the factory activity. The commercial activity was not essential to the existence of the industrial undertaking, so the exemption did not extend to it and the reference was answered against the assessee.</description>
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    <pubDate>Fri, 07 Feb 1964 00:00:00 +0530</pubDate>
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      <title>1964 (2) TMI 90 - CALCUTTA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=188592</link>
      <description>Profits exemption under section 15C was confined strictly to income derived from the industrial undertaking itself. The court held that the manufacture and sale of industrial gases and the separate commercial sale of equipment and allied goods constituted distinct undertakings because each could operate independently of the other. Applying a strict construction of section 15C, it further held that profits from the non-industrial business were not exempt merely because they were incidental or associated with the factory activity. The commercial activity was not essential to the existence of the industrial undertaking, so the exemption did not extend to it and the reference was answered against the assessee.</description>
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      <pubDate>Fri, 07 Feb 1964 00:00:00 +0530</pubDate>
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