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    <title>2021 (3) TMI 363 - MADRAS HIGH COURT</title>
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    <description>Deduction under Section 80IA was upheld for a new industrial undertaking because the assessee met the statutory conditions, including no transfer of previously used plant or machinery and engagement in an activity treated as manufacture or processing. The Tribunal&#039;s allowance was supported by the absence of material showing reuse of old machinery and by CBDT guidance and precedent treating film production as qualifying activity. The Revenue&#039;s later reliance on Section 80IA(7) was not accepted, as that contention had not been properly raised earlier and the surrounding record did not show any error in the Tribunal&#039;s reasoning.</description>
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      <description>Deduction under Section 80IA was upheld for a new industrial undertaking because the assessee met the statutory conditions, including no transfer of previously used plant or machinery and engagement in an activity treated as manufacture or processing. The Tribunal&#039;s allowance was supported by the absence of material showing reuse of old machinery and by CBDT guidance and precedent treating film production as qualifying activity. The Revenue&#039;s later reliance on Section 80IA(7) was not accepted, as that contention had not been properly raised earlier and the surrounding record did not show any error in the Tribunal&#039;s reasoning.</description>
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