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The ITAT upheld the Assessing Officer's determination that the assessee's inclusion of revenue from the sale of tradable licenses as "other income" under section 80IB(11A) was improper. The tribunal found that since the licenses were not utilized to offset customs duty on imports, the income derived from their sale did not reduce the cost of production. Consequently, such income could not be excluded from net profits eligible for deduction. The decision distinguished prior precedent relating to direct subsidies, emphasizing that export incentives must directly reduce production costs to qualify. The appeal was dismissed, affirming the disallowance of the deduction claimed on this account.
The ITAT upheld the Assessing Officer's determination that the assessee's inclusion of revenue from the sale of tradable licenses as "other income" under section 80IB(11A) was improper. The tribunal found that since the licenses were not utilized to offset customs duty on imports, the income derived from their sale did not reduce the cost of production. Consequently, such income could not be excluded from net profits eligible for deduction. The decision distinguished prior precedent relating to direct subsidies, emphasizing that export incentives must directly reduce production costs to qualify. The appeal was dismissed, affirming the disallowance of the deduction claimed on this account.
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