2007 (1) TMI 74

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....r of the Income-tax Appellate Tribunal in I.T.A. No.1629 and 1628/Mds/2002 dated May 12, 2006. 2.  The Revenue is the appellant.  During the relevant assessment years, viz., 1994-95 and 1998-99, the respective assessees claimed deduction under Section 80HHC in respect of export of film prints to foreign enterprises.  Initially, the claim of the assessees was allowed, but on re-open....

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....tion under section 80HHC ? 2. Whether in the facts and circumstances of the case, a transaction for transfer of exploitation rights, entered into in India can be eligible for the benefit of sec.80HHC only because the consideration was received in foreign exchange ?" 3.  Mr. J. Narayanaswamy, learned standing counsel appearing for the Revenue, fairly submits that the issues raised in the abo....