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    <description>Investment allowance under Section 32A was unavailable because the construction activity in question fell outside the scope of the provision as governed by the Supreme Court decision, so the issue was decided in favour of the Revenue. Guarantee commission paid for purchase of a capital asset was treated as revenue expenditure on the basis of an earlier Court decision, and the Tribunal&#039;s view did not give rise to a referable question of law, so this issue also went against the Revenue.</description>
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