DEPB sale proceeds under Section 80HHC follow Topman Exports, with the assessee's computation upheld.

DEPB sale proceeds were required to be computed for deduction under Section 80HHC in line with the Supreme Court's ruling in Topman Exports, including the treatment of receipts linked to Sections 28(iiid) and 28(iv). The governing precedent was applied to the export profit computation, and the assessee's position on the DEPB issue was accepted. The Revenue's challenge therefore failed, and the tax appeal was rejected on this point.

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Issues: Whether the receipt from sale of DEPB scrips was to be treated for computation of deduction under Section 80HHC of the Income-tax Act, 1961, including the effect of Sections 28(iv) and 28(iiid).

Analysis: The sole substantive controversy concerned the treatment of DEPB sale proceeds while computing deduction under Section 80HHC. The issue was held to be covered by the Supreme Court decision in Topman Exports, which governed the computation of export profits and the treatment of DEPB-related receipts under the Act.

Conclusion: The issue was answered in favour of the assessee. The Revenue's appeal failed.

Final Conclusion: The tax appeal was rejected, and the assessee's entitlement stood upheld on the DEPB computation issue.

Ratio Decidendi: Where the governing precedent squarely settles the treatment of DEPB receipts, the computation of deduction under Section 80HHC must follow that binding interpretation.

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