https://www.taxtmi.com/caselaws?id=785155 Section 80HHC deduction for an exporter with turnover below the prescribed threshold is addressed through the retrospective amendment introducing conditions in the third and fourth provisos. Supreme Court authority in Avani Exports treated exporters below and above that threshold similarly after addressing the severability of those conditions, preserving the deduction benefit. Applying that principle, the claimed deduction is allowable where the taxpayer's export turnover remained below the threshold and no distinguishing material exists. The Assessing Officer's and appellate authority's restriction based on the amended provisos and set-off rules does not displace that result. en-us Tue, 25 Nov 2025 00:00:00 +0530 Mon, 19 Jan 2026 07:36:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785155 Section 80HHC deduction for an exporter with turnover below the prescribed threshold is addressed through the retrospective amendment introducing conditions in the third and fourth provisos. Supreme Court authority in Avani Exports treated exporters below and above that threshold similarly after addressing the severability of those conditions, preserving the deduction benefit. Applying that principle, the claimed deduction is allowable where the taxpayer's export turnover remained below the threshold and no distinguishing material exists. The Assessing Officer's and appellate authority's restriction based on the amended provisos and set-off rules does not displace that result. Case-Laws Income Tax Tue, 25 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785155