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    <title>1997 (4) TMI 79 - Supreme Court</title>
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    <description>An exemption notification using the expression &quot;industrial unit&quot; distinct from &quot;factory&quot; was interpreted contextually, so capital investment had to be computed unit-wise rather than for the factory as a whole. The notification&#039;s earlier reference to clearances from one or more factories did not control the proviso, which deliberately used different language and was applied in line with excise practice and administrative understanding. On that construction, the tribunal&#039;s view that the exemption limit turned on the capital investment of each industrial unit was upheld, and the assessee&#039;s broader factory-based interpretation failed.</description>
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    <pubDate>Wed, 30 Apr 1997 00:00:00 +0530</pubDate>
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      <title>1997 (4) TMI 79 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=44550</link>
      <description>An exemption notification using the expression &quot;industrial unit&quot; distinct from &quot;factory&quot; was interpreted contextually, so capital investment had to be computed unit-wise rather than for the factory as a whole. The notification&#039;s earlier reference to clearances from one or more factories did not control the proviso, which deliberately used different language and was applied in line with excise practice and administrative understanding. On that construction, the tribunal&#039;s view that the exemption limit turned on the capital investment of each industrial unit was upheld, and the assessee&#039;s broader factory-based interpretation failed.</description>
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      <pubDate>Wed, 30 Apr 1997 00:00:00 +0530</pubDate>
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