1991 (12) TMI 35

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....hat the business of the assessee consisted of 100% export, it was not entitled to weighted deduction under section 35B of the Income-tax Act, 1961, on the entire expenses incurred of Rs. 5,70,026 in the assessment year 1976-77, of Rs. 17,77,304 in the assessment year 1977-78 and of Rs. 10,03,315 in the assessment year 1978-79 and claimed by it in the course of carrying on the business as per statement attached ? (2) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the appellant was not entitled to claim full relief of 100% under section 35B of the Act on the items of expenditure as per statement attached ? (3) Whether, on the facts and circumstances of the case, the Tribunal was ju....

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.... the Act in respect of the entire expenditure incurred by it. This claim for weighted deduction under section 35B was made in the course of income-tax assessments for the assessment years 1976-77 to 1978-79. The assessee was granted relief under section 35B of the Act in respect of the expenditure incurred by it for (i) foreign telegram charges ; (ii) foreign telephone charges ; (iii) 75% of salary paid to export staff ; (iv) ECGC Insurance expenses ; (v) export promotion expenditure ; and (vi) telex charges, either by the Income-tax Officer or by the Commissioner of Income-tax (Appeals). Therefore, the question before the Tribunal in the appeals preferred by the assessee was in respect of only the remaining items of expenditure. This, howe....