https://www.taxtmi.com/caselaws?id=16114 The dominant issues were whether the Tribunal could admit additional grounds, whether CCS receipts were taxable business profits, and whether certain export-related expenditures qualified for weighted deduction under s. 35B. Applying SC law, the HC held the Tribunal has discretion to permit new legal grounds arising from facts already on record to correctly determine tax liability; the issue was decided against the Revenue. On CCS, the HC held Finance Act, 1990 retrospectively inserted s. 28(iiib) and s. 2(24)(vb), deeming export cash assistance taxable as "profits and gains of business"; the issue was decided for the Revenue. Relying on SC and its own precedents, the HC held commission paid in India, export promotion, and export guarantee insurance expenditures did not fall within s. 35B(1)(b); each claim was rejected for the Revenue. en-us Fri, 19 Feb 1999 00:00:00 +0530 Fri, 19 Dec 2025 14:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16114 The dominant issues were whether the Tribunal could admit additional grounds, whether CCS receipts were taxable business profits, and whether certain export-related expenditures qualified for weighted deduction under s. 35B. Applying SC law, the HC held the Tribunal has discretion to permit new legal grounds arising from facts already on record to correctly determine tax liability; the issue was decided against the Revenue. On CCS, the HC held Finance Act, 1990 retrospectively inserted s. 28(iiib) and s. 2(24)(vb), deeming export cash assistance taxable as "profits and gains of business"; the issue was decided for the Revenue. Relying on SC and its own precedents, the HC held commission paid in India, export promotion, and export guarantee insurance expenditures did not fall within s. 35B(1)(b); each claim was rejected for the Revenue. Case-Laws Income Tax Fri, 19 Feb 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16114