https://www.taxtmi.com/caselaws?id=10026 The doctrine of merger operates where a High Court judgment on the stage of section 80HHC deduction is set aside on appeal on merits, so the earlier view cannot survive as an independent binding precedent. For composite tea income computed under rule 8, export deduction under section 80HHC is allowed at the computation stage before the statutory apportionment into agricultural and non-agricultural components. The legal fiction in rule 8 is confined to its limited purpose and does not postpone admissible deductions under the Act. The assessee therefore succeeds, and the export deduction is to be given effect first. en-us Tue, 24 Aug 2004 00:00:00 +0530 Mon, 13 Jun 2011 18:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=10026 The doctrine of merger operates where a High Court judgment on the stage of section 80HHC deduction is set aside on appeal on merits, so the earlier view cannot survive as an independent binding precedent. For composite tea income computed under rule 8, export deduction under section 80HHC is allowed at the computation stage before the statutory apportionment into agricultural and non-agricultural components. The legal fiction in rule 8 is confined to its limited purpose and does not postpone admissible deductions under the Act. The assessee therefore succeeds, and the export deduction is to be given effect first. Case-Laws Income Tax Tue, 24 Aug 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=10026