https://www.taxtmi.com/caselaws?id=14008 In construing s. 80HHC(1) read with s. 80HHC(3)(c), the HC held that "profit" in s. 80HHC(1) denotes only positive export profits and cannot include losses, as the provision is an incentive intended to grant deduction only to the extent export profits are earned; however, the computation under s. 80HHC(3)(c) must aggregate profits and losses, and a disclaimer cannot be used to ignore trading export losses so as to confer dual benefits on both the export house and supporting manufacturer. Consequently, where the aggregated computation results in an export loss, no deduction under s. 80HHC(1) is allowable. On s. 80-IA, the Tribunal's refusal to adjudicate on exclusion of certain income/expenses was set aside, and the issue was remanded for fresh decision; the remainder was affirmed. en-us Mon, 02 Jul 2001 00:00:00 +0530 Mon, 22 Dec 2025 16:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=14008 In construing s. 80HHC(1) read with s. 80HHC(3)(c), the HC held that "profit" in s. 80HHC(1) denotes only positive export profits and cannot include losses, as the provision is an incentive intended to grant deduction only to the extent export profits are earned; however, the computation under s. 80HHC(3)(c) must aggregate profits and losses, and a disclaimer cannot be used to ignore trading export losses so as to confer dual benefits on both the export house and supporting manufacturer. Consequently, where the aggregated computation results in an export loss, no deduction under s. 80HHC(1) is allowable. On s. 80-IA, the Tribunal's refusal to adjudicate on exclusion of certain income/expenses was set aside, and the issue was remanded for fresh decision; the remainder was affirmed. Case-Laws Income Tax Mon, 02 Jul 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=14008