Export of film exhibition and broadcasting rights qualifies for section 80HHC deduction, following earlier Bombay HC reasoning.

Export of overseas exhibition and broadcasting rights in cinematographic films, including licences for those rights, was treated as export of merchandise or goods for deduction under section 80HHC. The Bombay HC applied its earlier ruling on the same legal question and, on the parties' joint request, answered the question consistently with that decision. The operative effect was that such rights fell within the deduction provision, with the issue resolved in favour of the assessee and against the Revenue.

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Issues: Whether the export of overseas exhibition and broadcasting rights of cinematographic films, including licences for such rights, amounted to export of merchandise or goods so as to qualify for deduction under section 80HHC of the Income-tax Act, 1961.

Analysis: The appeals were disposed of by applying the court's earlier decision covering the same legal question. On the parties' joint request, the questions of law were answered in the same manner as in that decision, with the export of exhibition and broadcasting rights of cinematographic films treated as falling within the scope of the deduction provision.

Conclusion: The question was answered in favour of the assessee and against the Revenue.

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