Deduction under section 80HHC of the Income-tax Act, 1961, as amended by the Finance Act, 1990--Clarification regarding

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....rcular No.564, dated 5-7-1990 (See [1990] 184 ITR (St.) 137, explaining the deduction admissible under section 80HHC of the Income-tax Act, 1961, in respect of export profits. 2. In paragraph 5 of the aforesaid circular, it has been stated that the Finance Act, 1990, has amended section 28 of the Income-tax Act, by inserting therein clauses (iiia), (iiib) and (iiic) with retrospective effect wi....

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....der the head "Profits and gains of business or profession" with effect from 1-4-1967. The duty drawback has been so included with effect from 1-4-72. The profits on sale of import entitlement licences have been included with effect from 1-4-1962, the date from which the Income-tax Act, 1961, came into force. 4. The Department's view all along has been that these export incentives are revenue re....

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....tlement licences. 7. The amendment referred to above has been made with effect from 1-4-1991. Since the amendment only clarifies the legislative intention as it always existed, the position as regards the past years would be the same as that after coming into force of the amendment. In other words, the meaning of the term "total turnover" for the assessment year 1990-91 and earlier years, when ....