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    <title>2010 (8) TMI 333 - Karnataka High Court</title>
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    <description>Under section 80HHC, only receipts specifically covered by Explanation (baa), such as brokerage, commission, interest, rent, charges and similar income, are to be reduced from business profits by ninety per cent. A fee received for developmental work from a foreign enterprise, where earned in the course of export-related manufacturing activity and having a direct and immediate nexus with that business, is not an independent income of the same character as those exclusions. The mere availability of relief under section 80-O does not bring the receipt within Explanation (baa). Accordingly, such a receipt is not liable to the ninety per cent reduction when computing profits of business.</description>
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      <title>2010 (8) TMI 333 - Karnataka High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=202786</link>
      <description>Under section 80HHC, only receipts specifically covered by Explanation (baa), such as brokerage, commission, interest, rent, charges and similar income, are to be reduced from business profits by ninety per cent. A fee received for developmental work from a foreign enterprise, where earned in the course of export-related manufacturing activity and having a direct and immediate nexus with that business, is not an independent income of the same character as those exclusions. The mere availability of relief under section 80-O does not bring the receipt within Explanation (baa). Accordingly, such a receipt is not liable to the ninety per cent reduction when computing profits of business.</description>
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