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2012 (5) TMI 39 - HC - Income TaxNature of surrendered income - Claim of deduction under Section 80HHC - the assessee had taken the surrendered value of stock of bullion lying with karigarsas as business profits – Held that:- Deduction under Section 80HHC could be claimed only on showing facts which make an assessee eligible for the deduction - there was no presumption that the surrender made was on account of unexplained stocks representing the export income - burden to prove to said facts was on the assessee and not on the Revenue - there cannot be any presumption that the surrender made represents income from exports – against assessee.
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