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2011 (10) TMI 493 - ITAT DELHIRevision u/s 263 - for the purpose of deduction u/s 80-HHC turnover of 100% export oriented unit should be taken into account for determination of the total turnover - Held that: Since the assessee had not preferred any appeal against order of the CIT passed u/s 263 no ground relating to order u/s 263 can be taken in appeal against the order passed consequent to directions contained u/s 263 - Appeal dismissed. Deduction u/s 80HHC - whether turnover of 100% export unit be included in the total turnover of the business for the purpose of deduction u/s 80-HHC - Held that:- If the turnover of 100% export oriented unit is included in the total turnover the profits derived from the export unit which is not a 100% export oriented unit will always be a lower amount and thus the profits derived will be distorted one and will not be giving the correct export profits. Therefore, turnover of 100% export unit cannot be included in the total turnover for the purpose of computation of deduction u/s 80-HHC. Only the turnover which is in the nature of operating profits in respect of non-100% export oriented unit shall be considered for computation of deduction u/s 80-HHC - Decided in favor of assessee
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