Export profit computation redefined to apportion manufactured and trading export profits; transfers to foreign branches treated as exports. Amendments to section 80HHC treat sale proceeds credited to a separate foreign account with RBI approval as deemed received in India and deem transfers to an assessee's foreign branch followed by sale as exports, using the shipping bill value as sale proceeds. Profits from exported manufactured goods are apportioned by export turnover to total turnover; profits from exported trading goods equal export turnover less direct and indirect costs; mixed businesses use adjusted profits and turnovers excluding trading exports. Precise definitions of adjusted export turnover, adjusted profits, adjusted total turnover, direct costs, indirect costs and trading goods are provided.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Export profit computation redefined to apportion manufactured and trading export profits; transfers to foreign branches treated as exports.
Amendments to section 80HHC treat sale proceeds credited to a separate foreign account with RBI approval as deemed received in India and deem transfers to an assessee's foreign branch followed by sale as exports, using the shipping bill value as sale proceeds. Profits from exported manufactured goods are apportioned by export turnover to total turnover; profits from exported trading goods equal export turnover less direct and indirect costs; mixed businesses use adjusted profits and turnovers excluding trading exports. Precise definitions of adjusted export turnover, adjusted profits, adjusted total turnover, direct costs, indirect costs and trading goods are provided.
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