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    <title>2019 (2) TMI 1061 - ITAT MUMBAI</title>
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    <description>Incentives by way of excise duty refund and sales tax exemption for industrial units in Kutch were treated as capital receipts because the schemes were aimed at inducing new investment, employment, and regional development; they were therefore not chargeable to tax and did not reduce actual cost under section 43(1). For section 14A, the existence of own funds exceeding investments meant no interest disallowance was justified under rule 8D, but the administrative expenditure component required fresh examination. The remaining disputes, including premature redemption, book profit adjustments, penalties, and alleged bogus purchases, were remitted for de novo adjudication on proper facts and law.</description>
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      <description>Incentives by way of excise duty refund and sales tax exemption for industrial units in Kutch were treated as capital receipts because the schemes were aimed at inducing new investment, employment, and regional development; they were therefore not chargeable to tax and did not reduce actual cost under section 43(1). For section 14A, the existence of own funds exceeding investments meant no interest disallowance was justified under rule 8D, but the administrative expenditure component required fresh examination. The remaining disputes, including premature redemption, book profit adjustments, penalties, and alleged bogus purchases, were remitted for de novo adjudication on proper facts and law.</description>
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