2011 (4) TMI 1159

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.... JUDGMENT N. Kumar, J. - These two appeals are preferred by the revenue challenging the order passed by the tribunal which has held the receipts from sub contract services and sale of scrap material do not fall within the definition of Explanation (baa) to Section 80HHC(1) of the Income Tax Act, 1961. 2. The assessee is a manufacturer of commutators. It also manufactures certain goods on ....

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....'s appeals to the tribunal came to be dismissed. It is thereafter, they have preferred this appeal. 3. The appeal was admitted to consider the following substantial questions of law in ITA 22/08 and respectively: "Whether the Appellate Authorities were correct in holding that 90% of the income derived from scrap sales and other sub-contract services cannot be excluded when computing the prof....

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....estion of law such as 'Miscellaneous expenses and hire charges' are deleted. 4. From the material on record, it is clear that the assessee is in the business of manufacture of commutators and they export the commutators after manufacturing and they have export income. They also manufacture certain products which are sold locally. The scrap which is sold is generated in the course of the manufac....