2012 (9) TMI 401

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....pertains to the Assessment Year 2003-04. In this year, the assessee had claimed deduction under Section 80HHD of the Income-Tax Act qua convertible foreign exchange earned during the year, which was rejected by the Assessing Officer holding that these receipts do not qualify for the deduction under the aforesaid provision, which is available for the earning of foreign exchange from providing servi....

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.... as "profits of the business". There cannot be any dispute that the income from the money exchange business is a business income as the assessee has, by the said activity, earned profits. It is clear that the assessee had never claimed the aforesaid income as income entitled to deduction under Section 80HHD of the Act. The only effect of that was to treat it as part of the profits of the business ....