1998 (6) TMI 64

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....urt under section 256(2) of the Income-tax Act, 1961, the Income-tax Appellate Tribunal referred the following questions for the opinion of this court : "(1) Whether, on the facts and in the circumstances of the case, the Tribunal is right in holding that the assessee is entitled to a deduction under section 80HH on the income by way of sale of import licence, export house premium and customs d....

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....aking. Profit or gain can be said to have been derived from an activity carried on by a person only if the said activity is an immediate and effective source of the said profit or gain. The Division Bench also held that, "there is no trace of any factual material to ascertain whether the amount can be said to have derived from business activity with reference to the industrial undertaking as is cl....