Section 80HHC deduction denied for export profits where prior High Court interpretation controlled identical facts.

Section 80HHC was applied to deny deduction on export profits for assessment year 1988-89, because the issue had already been decided by an earlier Madras High Court ruling on the same provision and the same assessment year. That prior construction of section 80HHC was followed on identical facts, and the assessee's claim was rejected. The court treated the earlier interpretation as controlling and held that the deduction could not be claimed contrary to that settled view.

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Issues: Whether the assessee was entitled to deduction under section 80HHC of the Income-tax Act, 1961, in respect of export profits for the assessment year 1988-89.

Analysis: The issue was covered by an earlier decision of the same Court, which had held that the assessee was not entitled to the benefit claimed under section 80HHC for the relevant assessment year. The reasoning in that decision was applied to the present case, and the facts were not disputed.

Conclusion: The assessee was not entitled to deduction under section 80HHC of the Income-tax Act, 1961, for the assessment year 1988-89.

Ratio Decidendi: Where the Court has already interpreted section 80HHC in relation to export profits for the relevant assessment year, the same construction governs later cases on identical facts and the deduction cannot be claimed contrary to that interpretation.

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