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The Tribunal held that a retracted statement, without corroborating evidence, cannot be considered incriminating material for making additions in a completed assessment. The High Court agreed that no substantial question of law arose.
The High Court held that excise duty exemption, when granted as an incentive for industrialization and employment generation in backward areas, is a capital receipt. Consequently, it cannot be taxed under normal provisions and should not be included in book profit for MAT computation.