Separate Units Separate Investment Rajasthan HC Bars Clubbing for MSME Tax Benefit

The Court dismissed the Revenue’s six revision petitions and upheld the Rajasthan Tax Board’s decision in favour of Khandeliya Udhyog Pvt. Ltd. The ruling rests on the wording of the State’s amended notification, which expressly prohibited clubbing investment in different enterprises under the same ownership, and the Revenue’s failure to establish common funding or mutual business interest between the units.