833/CBDT.

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..... d is debited to the profit and loss account of the relevant previous year and credited to the reserve account to be utilised by the assessee during a period of eight years next following for the purpose of the business of the undertaking. However, the first proviso to the above section provides that the above condition shall not apply where the assessee is a company being a licensee within the mea .....

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..... Act, 1948 is subject to the provisions of section 2(6) of the Act. In view of the definition of licensee given in section 2(6) which specifically excludes the Board the State Electricity Boards will not be regarded as licensee and consequently not entitled to the benefit of the first proviso to section n4(3)(a) of the Income-tax Act, 1961. 4. In view of the opinion of the Ministry of Law, the B .....

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