https://www.taxtmi.com/caselaws?id=799381 Premium earned on a domestic transfer of export quota does not fall within the export-incentive receipts specified in Sections 28(iiia) to 28(iiic and therefore does not qualify for the Section 80HHC deduction. Departmental circulars and administrative instructions bind Revenue authorities but cannot bind constitutional courts or override statutory provisions and judicial interpretation. The CBDT Office Memorandum's treatment of export-quota premium as a specified incentive creates a legal fiction inconsistent with the statutory scheme, since such premium lacks the foreign-exchange character and other essential attributes of the enumerated receipts. en-us Fri, 18 Sep 2026 00:00:00 +0530 Mon, 21 Sep 2026 08:57:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799381 Premium earned on a domestic transfer of export quota does not fall within the export-incentive receipts specified in Sections 28(iiia) to 28(iiic and therefore does not qualify for the Section 80HHC deduction. Departmental circulars and administrative instructions bind Revenue authorities but cannot bind constitutional courts or override statutory provisions and judicial interpretation. The CBDT Office Memorandum's treatment of export-quota premium as a specified incentive creates a legal fiction inconsistent with the statutory scheme, since such premium lacks the foreign-exchange character and other essential attributes of the enumerated receipts. Case-Laws Income Tax Fri, 18 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799381