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2005 (3) TMI 75 - KERALA HIGH COURTDeduction under the proviso to sub-section (3) of section 80HHC - Whether turnover on sales to export house undertaken by the assessee as a supporting manufacturer be included in the "export turnover" for the purpose of computation of deduction under the proviso to sub-section (3) of section 80HHC of the Income-tax Act, 1961 - We are of the view that the benefits available to exporter and supporting manufacturer have to be separately computed in accordance with the specific provisions of the Act. While section 80HHC(1) read with section 80HHC(3) provides for computation and deduction of profit on direct exports, section 80HHC(1A) read with section 80HHC(3A) provides for computation and deduction of export profit for a supporting manufacturer. Since sales turnover of sales made by the appellant to the export houses do not answer the description of "export turnover" provided that the definition clause noted by us above, the Assessing Officer rightly excluded such turnover from export turnover while computing relief available to the appellant under the proviso to section 80HHC(3)
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