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2022 (8) TMI 360 - MADRAS HIGH COURTComputation of Deduction u/s 80HHC - as per assessee there were export earnings and hence, the negative profit as 'Nil' should be taken into consideration for computation of deduction under section 80HHC - deduction should be taken as a whole and the loss derived by the assessee from one limb of the business should be set off against the profit of other limb of the business - HELD THAT:- As in view was followed in the subsequent decision of the Hon'ble Supreme Court in CIT v. K.Ravindranathan Nair [2007 (11) TMI 10 - SUPREME COURT] in which it was categorically stated that "for computation of deduction under section 80HHC(3)(c), losses suffered by the assessee in the export of trading goods are to be set off / adjusted against profits from export of manufactured goods and vice versa and the assessee would not be entitled to deduction, if after such adjustments/ set off the net figure is a loss" Applying the aforesaid legal proposition to the facts of the present case, this court is of the view that there is no infirmity in the order so passed by the Tribunal, warranting interference. As such, the substantial question of law raised herein is answered in favour of the Revenue.
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