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The High Court of Madras ruled that the subsidy received by the assessee under the Central Investment Outright Subsidy Scheme should be treated as a reserve for computing the capital base under the Companies (Profits) Surtax Act. The subsidy, though not considered a profit, was available for business use and could help reduce industry costs. The court held in favor of the assessee, stating that the subsidy could be treated as a reserve and included in capital computation.
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