Section 80IA deduction for duty drawback and REP licence profits was allowed by applying the earlier Section 80IB ruling.

Deduction under Section 80IA of the Income-tax Act was considered in relation to duty drawback and profit on sale of REP licences. The Delhi High Court noted that the language of Sections 80IA and 80IB on the issue was virtually identical and applied the earlier Section 80IB decision to the present controversy. On that basis, the court held the deduction could not be denied for those receipts, answered the issue in favour of the assessee, and set aside the disallowance to that extent.

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Issues: Whether deduction under Section 80IA of the Income-tax Act, 1961 was available on duty drawback and profit on sale of REP licences.

Analysis: The language of Sections 80IA and 80IB, in relation to the question raised, was held to be virtually identical. The answer adopted in the earlier decision on Section 80IB was applied to the present controversy, and the issue was decided consistently with that view.

Conclusion: The issue was answered in favour of the assessee and against the revenue, and the denial of deduction was set aside to that extent.

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