Judgment

TULZAPURKAR, J.:- Two contentions under a Scheme called "Tax Credit Certificate (Excise Duty on Excess Clearance) Scheme, 1965" framed by the Central Government under S. 280ZD of the Income Tax Act, 1961, which were, negatived by the High Court, have again been pressed by the appellant company before us in these appeals but after hearing counsel for the appellant company at some length and after going through the relevant provisions of the said Scheme, relevant sections of the Income Tax Act, 1961 and S. 80 of the Finance Act 1965 we are satisfied that the High Court was right in the view which it took on both the contentions and the appeals deserve to be dismissed.

2. With a view to encourage investment in new equity shares and to stimulate industrial output the Government of India introduced certain special provisions in Chapter XXII-B of the Income Tax Act, 1961 for the grant of tax. credit certificate and S. 280ZD is one of such provisions which provides for the grant of tax credit certificate by way of incentive for increased production of goods and the "Tax Certificate (Excise Duty on Excess Clearance) Scheme 1965" was framed by the Central Government under this sectio