2009 (12) TMI 575

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....are raised in the connected appeals filed by the assessee for the assessment years 2000-01, 2002-03 and 2003-04.   2. We have heard advocate Sri P. Balakrishnan, appearing for the appellant and standing counsel appearing for the respondent.   3. The first question pertains to the disallowance of deduction claimed for exemption under section 80HHC of the Income-tax Act, 1961. The as....

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....ourt in IPCA Laboratory v. Deputy CIT [2004] 266 ITR 521 wherein the Supreme Court has clearly held that unless profit is derived by the exporters in respect of the export, the supporting manufacturer is not entitled to deduction based on the disclaimer certificate issued which in this case produced by the appellant shows that exports resulted in loss to the exporters. We, there-fore, do not find ....