2014 (12) TMI 806

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....nt and order dated 27.10.2004 passed by the Income Tax Appellate Tribunal, Ahmedabad Bench 'B', in ITA No. 2450/A/2004 for AY 2001-02. 2. While admitting this appeal, this Court has framed the following substantial questions of law:     (1) Whether on the facts and circumstances of the case and in law the Hon'ble Tribunal was justified in holding that the exchange rate....

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....No. 10CCAC i.e. the claim by the exporter for the deduction u/s. 80HHC of the Act. The case was selected under scrutiny and notice under sec. 143(2) of the IT Act was issued on31.1.2002 and the same was served upon the assessee on 1.2.02. In response to the notice, the assessee has filed all the details called for from time to time. After considering the material on record, the assessment order ca....

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....sp;  "that the source of the income of the assessee was the export. On the basis of accrual, income was already reflected in the assessee's account on the date of the export at the prevailing rate of exchange. Further, the income was earned merely on account of foreign exchange fluctuation. Such income, therefore, was directly related to the assessee's export business and could n....