Exemption from income-tax to the extent of six per cent per annum of the capital employed.

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..... n 80-J are entitled to exemption from income-tax to the extent of six per cent per annum of the capital employed. In certain cases the deduction is at the rate of seven and a half percent. A question may arise as to what meaning should be attached to words "per annum". As per Concise Oxford Dictionary, the meaning of the words "per annum" is (so much) by the year, yearly. The Board were earlier ad .....

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..... ing allowance of relief on pro-rata basis. There is no direct decision of any High Court on this point so far and even in the case of Union of India Vs Coromondel Fertilizer Ltd. 102-ITR-533, 542 the assessee though allowed relief under Section 80-J in proportion to the period during which the new industrial undertaking was in operation did not contest it before the Court. Then there are conflicti .....

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