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    <description>Concurrent findings of fact based on books of account, audit material and surrounding circumstances were treated as insufficient to raise a substantial question of law unless shown to be perverse or unsupported by evidence. On the section 10A claim, the Tribunal&#039;s findings on manufacturing activity, electricity consumption, labour charges and FIFO adjustment were left undisturbed, subject only to limited verification already ordered. The same approach applied to additions under sections 68 and 69C and to the claims relating to diamond trade loss, forward contract loss and interest disallowance, which were largely held to be factual matters. Only the short-deduction TDS issue under section 40(a)(ia) was admitted as a substantial question of law.</description>
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