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    <description>Foreign travelling expense disallowance requires adequate factual examination where the record does not clearly establish the basis for sales promotion or conference-related claims; the matter was remitted for fresh adjudication. Duty drawback was treated as having a direct and immediate nexus with export production, so it qualified as profits and gains &quot;derived from&quot; an industrial undertaking for deduction under sections 80HH and 80-I. The distinction drawn was that the receipt was a reimbursement linked to the cost of export production, unlike more remote receipts such as import entitlements. The stated ratio is that a deduction applies only where the receipt is directly connected with the undertaking&#039;s operations.</description>
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      <description>Foreign travelling expense disallowance requires adequate factual examination where the record does not clearly establish the basis for sales promotion or conference-related claims; the matter was remitted for fresh adjudication. Duty drawback was treated as having a direct and immediate nexus with export production, so it qualified as profits and gains &quot;derived from&quot; an industrial undertaking for deduction under sections 80HH and 80-I. The distinction drawn was that the receipt was a reimbursement linked to the cost of export production, unlike more remote receipts such as import entitlements. The stated ratio is that a deduction applies only where the receipt is directly connected with the undertaking&#039;s operations.</description>
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