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    <title>2026 (8) TMI 544 - ITAT MUMBAI</title>
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    <description>Dispensing units installed at petroleum retail outlets qualify as new plant or machinery for investment allowance where refining, marketing and retail sale form one integrated and indivisible business of manufacture or production. The units were accepted as plant and machinery for depreciation and were not excluded from the statutory definition. As regulated petrol and diesel sales require dispensing units at the terminal retail stage, the assets need not be directly used in the physical manufacturing process. The relevant requirement is that the company is engaged in manufacture or production. Accordingly, such dispensing units are eligible for investment allowance under section 32AC.</description>
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      <title>2026 (8) TMI 544 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=796671</link>
      <description>Dispensing units installed at petroleum retail outlets qualify as new plant or machinery for investment allowance where refining, marketing and retail sale form one integrated and indivisible business of manufacture or production. The units were accepted as plant and machinery for depreciation and were not excluded from the statutory definition. As regulated petrol and diesel sales require dispensing units at the terminal retail stage, the assets need not be directly used in the physical manufacturing process. The relevant requirement is that the company is engaged in manufacture or production. Accordingly, such dispensing units are eligible for investment allowance under section 32AC.</description>
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