2008 (2) TMI 407

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..... delivered by DEEPAK VERMA J.- Heard Sri M. V. Seshachala, learned counsel for the appellants and Sri S. Parthasarathi, learned counsel for the respondent. 2. This appeal is at the instance of the Revenue under section 260A of the Income-tax Act, 1961, against the order passed by the Income-tax Appellate Tribunal on March 21, 2003, in I. T. A. No. 226/Bang/1998. The following substantial questio .....

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..... te): "The word 'profit' in section 80HHC(1) and (3) of the Income-tax Act, 1961, means a positive profit. A plain reading of sub-section (3)(c) shows that 'profits from such exports' has to be profits from exports of self-manufactured goods plus profits from exports of trading goods. The profit is to be calculated in the manner laid down in sub-section (3)(c)(i) and (ii). The opening words 'profi .....

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..... nterpretation has to be given to such a provision, interpretation has to be as per the wording of the section. If the wording of the section is clear, then the benefits which are not available under the section can not be conferred by ignoring or misinterpreting words in the section." 5. In the light of the aforesaid judgments, the question of law framed has been answered in favour of the Revenue .....

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