https://www.taxtmi.com/caselaws?id=2470 SC allowed assessee's appeals regarding export incentive deduction under section 80HHC. The court held that where assessee earned export income plus other income with common pool of expenses, principle of attribution requires apportionment of indirect costs. Rather than complex actual allocation, court approved using 10% of other income as guidance value for expense attribution. This balances attribution principle with allocation concept, reducing but not eliminating export incentive. HC judgment set aside, Income Tax Appellate Tribunal orders restored. en-us Tue, 20 Nov 2007 00:00:00 +0530 Fri, 21 Feb 2025 16:24:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=2470 SC allowed assessee's appeals regarding export incentive deduction under section 80HHC. The court held that where assessee earned export income plus other income with common pool of expenses, principle of attribution requires apportionment of indirect costs. Rather than complex actual allocation, court approved using 10% of other income as guidance value for expense attribution. This balances attribution principle with allocation concept, reducing but not eliminating export incentive. HC judgment set aside, Income Tax Appellate Tribunal orders restored. Case-Laws Income Tax Tue, 20 Nov 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=2470