https://www.taxtmi.com/caselaws?id=166998 Whether interest on FDRs constitutes "business income" for deduction under s. 80HHC, the HC held it does not, as such interest is not derived from export business and, post insertion of Explanation (baa) w.e.f. 1-4-1992, must be excluded while computing eligible profits; consequently, deduction could not be allowed by treating it as business income. The assessee's plea of consistency based on prior years' treatment was rejected because an erroneous past approach cannot override the statutory scheme after Explanation (baa), and the AO was justified in taking a different view for AYs 1997-98 and 1998-99; accordingly, the Tribunal's orders were set aside, the Department's appeals were allowed, and s. 80HHC relief was directed to be recomputed without such interest. en-us Fri, 19 Jan 2007 00:00:00 +0530 Sat, 03 Jan 2026 13:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=166998 Whether interest on FDRs constitutes "business income" for deduction under s. 80HHC, the HC held it does not, as such interest is not derived from export business and, post insertion of Explanation (baa) w.e.f. 1-4-1992, must be excluded while computing eligible profits; consequently, deduction could not be allowed by treating it as business income. The assessee's plea of consistency based on prior years' treatment was rejected because an erroneous past approach cannot override the statutory scheme after Explanation (baa), and the AO was justified in taking a different view for AYs 1997-98 and 1998-99; accordingly, the Tribunal's orders were set aside, the Department's appeals were allowed, and s. 80HHC relief was directed to be recomputed without such interest. Case-Laws Income Tax Fri, 19 Jan 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=166998