Deduction under section 80HHC applies after allocation of composite profits under rule 8, reducing taxable export income. The circular directs that the deduction under section 80HHC for tea growers and manufacturers is to be allowed only after the composite profit is allocated under rule 8 to determine the income chargeable to tax under 'Profits and gains of business and profession'; the deduction is then computed with reference to that taxable business portion and apportioned in relation to export turnover.
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Provisions expressly mentioned in the judgment/order text.
Deduction under section 80HHC applies after allocation of composite profits under rule 8, reducing taxable export income.
The circular directs that the deduction under section 80HHC for tea growers and manufacturers is to be allowed only after the composite profit is allocated under rule 8 to determine the income chargeable to tax under "Profits and gains of business and profession"; the deduction is then computed with reference to that taxable business portion and apportioned in relation to export turnover.
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