https://www.taxtmi.com/caselaws?id=59510 In computing deduction under section 80HHC(3)(b) for export of trading goods, indirect costs must be confined to costs attributable to export turnover, and a reasonable apportionment is permitted where part of the receipts consists of export incentives. The controlling words "attributable to such export" require exclusion of the portion of common expenditure referable to non-export receipts, and the scheme of the provision, the explanatory memorandum and the Board circular support that approach. On that basis, indirect costs cannot be treated as wholly referable to exports when export incentives are also earned, and the assessee's method of excluding 10 per cent of such incentives from indirect costs is accepted in principle. en-us Thu, 12 Dec 2002 00:00:00 +0530 Fri, 26 Dec 2025 11:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59510 In computing deduction under section 80HHC(3)(b) for export of trading goods, indirect costs must be confined to costs attributable to export turnover, and a reasonable apportionment is permitted where part of the receipts consists of export incentives. The controlling words "attributable to such export" require exclusion of the portion of common expenditure referable to non-export receipts, and the scheme of the provision, the explanatory memorandum and the Board circular support that approach. On that basis, indirect costs cannot be treated as wholly referable to exports when export incentives are also earned, and the assessee's method of excluding 10 per cent of such incentives from indirect costs is accepted in principle. Case-Laws Income Tax Thu, 12 Dec 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59510