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    <description>Producing cinematographic films was treated as an industrial undertaking for section 80J relief because the activity was regarded as involving manufacture or processing, and the CBDT circular treating film production as industrial in nature was relied on as binding on the department. The Tribunal also viewed the assessee&#039;s activity as a factual matter rather than a pure question of law. On that basis, no referable question of law was found and the proposed reference was declined.</description>
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      <description>Producing cinematographic films was treated as an industrial undertaking for section 80J relief because the activity was regarded as involving manufacture or processing, and the CBDT circular treating film production as industrial in nature was relied on as binding on the department. The Tribunal also viewed the assessee&#039;s activity as a factual matter rather than a pure question of law. On that basis, no referable question of law was found and the proposed reference was declined.</description>
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