Set up, means a unit cannot be said to have been set up, unless it is ready to discharge the function for which it is being set up. It is only when the unit has been put into such a shape that it can start functioning as a business or a manufacturing organization that it can be said that the unit has been set up. The word 'set up' in the principal clause is equivalent to the word established, CWT Madras v. RS Cotton Mills, AIR 1967 SC 509: (1967) 1 SCJ 123: (1967) 1 ITJ 1: (1967) 1 Andh WR (SC) 25: (1967) 1 Mad LJ (SC) 25: (1967) 63 ITR 478.
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