Export-linked incentives are not deductible under Section 80-IB when they arise only after manufacture and export.

Export-linked incentives arising only after manufacture and upon export were held outside deduction under Section 80-IB of the Income-tax Act, because the claim was governed by Liberty India. Meghalaya Steels Limited was distinguished as concerning transport subsidy and reimbursement of manufacturing cost in the North-Eastern region, so the earlier law remained unaffected. On the facts considered, export incentives were not deductible under Section 80-IB and the special leave petition was dismissed.

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Issues: Whether export incentives are entitled to deduction under Section 80-IB of the Income-tax Act, 1961.

Analysis: The issue was held to be covered by the earlier decision in Liberty India, and the later decision in Meghalaya Steels Limited was distinguished as dealing with transport subsidy, being reimbursement of manufacturing cost in the North-Eastern region, whereas the present claim concerned export-linked incentives arising only after manufacture and upon export of goods. The earlier law was treated as unaffected.

Conclusion: Export incentives are not deductible under Section 80-IB of the Income-tax Act, 1961 on the facts considered, and the special leave petition was dismissed.

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