https://www.taxtmi.com/highlights?id=103992 Export quota premium is not equivalent to export-incentive receipts eligible for deduction under section 80HHC. Administrative circulars bind departmental authorities but cannot bind courts, override statutory language, or displace judicial interpretation. Equating premium from the transfer of export quota with receipts covered by the specified export-incentive provisions would create an impermissible legal fiction, particularly because such premium lacks characteristics of those receipts, including foreign-exchange realisation. Tax deductions must be construed strictly by reference to income derived and the statutory classification of eligible receipts; export quota premium therefore falls outside the claimed deduction. en-us Mon, 21 Sep 2026 08:57:05 +0530 Mon, 21 Sep 2026 08:57:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103992 Export quota premium is not equivalent to export-incentive receipts eligible for deduction under section 80HHC. Administrative circulars bind departmental authorities but cannot bind courts, override statutory language, or displace judicial interpretation. Equating premium from the transfer of export quota with receipts covered by the specified export-incentive provisions would create an impermissible legal fiction, particularly because such premium lacks characteristics of those receipts, including foreign-exchange realisation. Tax deductions must be construed strictly by reference to income derived and the statutory classification of eligible receipts; export quota premium therefore falls outside the claimed deduction. Highlights Income Tax Mon, 21 Sep 2026 08:57:05 +0530 https://www.taxtmi.com/highlights?id=103992