Section 80HHC deduction includes commission-related export income under binding Supreme Court precedent.

Commission income and commission received on assignment of export orders to another party in India were treated as part of profits eligible for deduction under section 80HHC, because the issue was already covered by the Supreme Court decisions in P. R. Prabhakar v. CIT and CIT v. Baby Marine Exports. Applying those binding authorities, the court found no further examination necessary and answered the questions against the Revenue and in favour of the assessee.

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Issues: Whether, for the purpose of deduction under section 80HHC, the profits computed under the head "profits and gains of business or profession" including commission income and commission received on assignment of export orders to another party in India are to be taken into account.

Analysis: The questions were covered by the Supreme Court decisions in P. R. Prabhakar v. CIT and CIT v. Baby Marine Exports, under which such commission-related income was treated as falling within the scope of profits eligible for deduction under section 80HHC. In view of those binding decisions, no further examination of the questions was necessary.

Conclusion: The questions were answered against the Revenue and in favour of the assessee.

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