Section 80IA and Section 80HHC deductions can both be claimed, subject to profits-based limits on total deduction.

Deduction under Section 80IA must be factored into the computation of profits and gains from export business, and the aggregate deduction cannot exceed the business profits. The legal position was treated as no longer res integra, and the tribunal's view was found consistent with that position. On that basis, the assessee was entitled to claim deductions under both Section 80IA and Section 80HHC of the Income-tax Act, 1961, and the revenue's challenge failed.

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Issues: Whether the assessee was entitled to claim deductions under both Section 80IA and Section 80HHC of the Income-tax Act, 1961.

Analysis: The deduction under Section 80IA is to be taken into account while computing profits and gains from export business, and the total deduction allowable cannot exceed the profits and gains of the business. The issue was treated as no longer res integra, and the tribunal's view was found to be consistent with the governing legal position.

Conclusion: The assessee was entitled to the benefit of deductions under both provisions, and the revenue's challenge failed.

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