https://www.taxtmi.com/caselaws?id=6110 The dominant issue was whether "counter sales" constituted "export out of India" for deduction under s. 80HHC, applying Explanation (aa) to s. 80HHC(4A). The SC held that where the transactions involved customs clearance within the meaning of Explanation (aa) and the sale proceeds were received in convertible foreign exchange, the statutory conditions for treating such sales as export profits were satisfied. The SC also relied on the Revenue's consistent acceptance of the legal position settled by an earlier HC decision, including in the same assessee's case, and found no basis to depart from it. The Revenue's appeal was dismissed and the deduction was upheld. en-us Wed, 18 Dec 2002 00:00:00 +0530 Fri, 26 Dec 2025 10:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6110 The dominant issue was whether "counter sales" constituted "export out of India" for deduction under s. 80HHC, applying Explanation (aa) to s. 80HHC(4A). The SC held that where the transactions involved customs clearance within the meaning of Explanation (aa) and the sale proceeds were received in convertible foreign exchange, the statutory conditions for treating such sales as export profits were satisfied. The SC also relied on the Revenue's consistent acceptance of the legal position settled by an earlier HC decision, including in the same assessee's case, and found no basis to depart from it. The Revenue's appeal was dismissed and the deduction was upheld. Case-Laws Income Tax Wed, 18 Dec 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6110