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    <description>Construction activity that does not amount to manufacture or production of an article or thing does not qualify for investment allowance under section 32A of the Income-tax Act, 1961, so the claim failed. A delegated amendment rule cannot operate retrospectively unless that intention is expressed, and rule 3(c) of the Companies (Acceptance of Deposits) Amendment Rules, 1981 did not apply to an accounting period that had already ended before its commencement. The reference was therefore answered partly for the Revenue and partly for the assessee.</description>
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