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    <description>Deduction claims relating to the Area Development Fund required factual examination of whether the collections were actually used for the purpose for which they were made and whether they were impressed with a specific legal obligation. The earlier Supreme Court ruling had explained the nature of the fund while leaving that factual contention open. As the Commissioner (Appeals) and the Tribunal had not recorded the necessary finding on utilisation and had not examined the relevant aspects adequately, the HC set aside the impugned orders and remanded the appeals for fresh decision in accordance with law.</description>
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