2000 (12) TMI 762

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....r 1993-94 is relating to the computation of deduction under section 80HHC in respect of exports. Rival contentions have been heard and record perused. 2. The relevant facts in this case are that the assessee is a manufacturer and 100 per cent exporter of Incandescents, its parts and chemicals. The assessee had received a sum of Rs. 3,22,273 on encashment of exim-scrip/RRP Licences from the Govern....

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....d Rs. 24,153 IPRS reimbursement). It is the claim of the department that exim-scrip premium paid by the Government does not fall within any of the clauses viz. (iiia), (iiib ) and (iiic) of section 28 and therefore 90 per cent of the said amount is not includible in the export profits by virtue of sub-section (3) read with provision thereto and Explanation (baa) to section 80HHC. The claim of the ....

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....ash assistance by whatever name called" received as against exports under the Scheme of Government of India. In this case the assessee had been granted exim-scrips by the Government of India as incentive for exports. The premium paid on surrender of exim-scrips granted by the Government of India thus falls within the expression "cash assistance by whatever name called" received or receivable by an....