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2012 (8) TMI 147 - KARNATAKA HIGH COURTDeduction under Section 80HHC of the Income Tax Act – Held that:- While computing the export profit on trading of goods under Section 80HHC(3)(b) of the Act the indirect costs allocable should be in accordance with Explanation (e) even when the indirect costs attributable to such export was identifiable and allocable - When once the assessee has not pointed out the indirect cost attributable to the export and contends that there was no indirect cost attributable to export, the same cannot be accepted and therefore, indirect costs have to be calculated in accordance with law - While so calculating, all the expenses involving indirect cost have to be included and no items can be excluded as done by the first appellate authority and therefore, the order passed by the ITAT directing the assessing officer to pass fresh orders after computing indirect cost in proportion to all the indirect costs incurred by the assessee attributable to export in the proportion inferred to in the order, is justified - in favour of the revenue
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