2007 (1) TMI 134

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....irected against the order of the Income-tax Appellate Tribunal made in I. T. A. No. 1261/Mds/2002, dated April 28, 2006. The Revenue is the appellant. The assessment year involved is 1997-98. The assessee is carrying on business of manufacture and sale of jewellery, gold ornaments at Chennai under the name of Bapalal and Co. and also exporting diamonds and precious stones from Bombay under t....

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....export profits are arrived at by deducting expenditure relating to export. Hence, the present appeal by the Revenue raising the following substantial question of law: "Whether on the facts and in the circumstances of the case, the Tribunal was right in holding that the provisions of section 80HHC (3) are not applicable to the assessee's case?" Mr. J. Narayanaswamy, learned standing counsel a....

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..... (b) where the export out of India is of trading goods, the profits derived from such export shall be the export turnover in respect of such trading goods as reduced by the direct costs and indirect costs attributable to such export ;" This court, in CIT v. Rathore Brothers [2002] 254 ITR 656, referred to supra, finding that the assessee therein had maintained separate accounts and it had m....