2002 (10) TMI 90

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....e question referred to us, at the instance of the Revenue, for our consideration is, "Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in holding that interest on amount deposited as guarantee fund forms part of profit derived from the export business and should be included in the profit of the assessment for computing deductions under sections 80HH, 80H....

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....ndertaking. The interest received on deposits cannot be regarded as income derived from the industrial undertaking but as it is derived from the deposits made by the assessee with the bank. The direct and proximate link is with the deposit in the bank and not with the industrial undertaking. In so far as section 80HHC is concerned, it stands on a different footing as sub-section (3) of section ....