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Issues: Whether weighted deduction under section 35B(1)(b) of the Income-tax Act, 1961 was allowable in respect of packing and forwarding expenses and import licence fee.
Analysis: Weighted deduction under section 35B required the expenditure to be incurred wholly and exclusively for activities performed outside India and in connection with or incidental to export-related contracts. Packing and forwarding expenses were incurred within India before export, and import licence fee was also not an expense incurred outside India. The assessee therefore failed to satisfy the statutory requirement.
Conclusion: The claim for weighted deduction on both heads was not allowable, and the answer to the question referred was in the negative, in favour of the Revenue.
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