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TMI Blog2011 (11) TMI 428X X X X Extracts X X X X X X X X Extracts X X X X ..... 10A – Held that:- To ascertain the profits from export business the total profits of the business are to be apportioned on the basis of turnovers. If the export turnover in the numerator is to be arrived at after excluding certain expenses, the same should also be excluded in computing the export turnover as a component of total turnover in the denominator. The reason being the total turnover incl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... formity in the ingredients of both the numerator and the denominator of the formula, since otherwise it would produce anomalies or absurd results. Section 10-A is a beneficial section. It is intended to provide incentives to promote exports. The incentive is to exempt profits relatable to exports. In the case of combined business of an assessee, having export business and domestic business, the le ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... over, there would be a commonality between the numerator and the denominator of the formula. In view of the commonality, the understanding should also be the same. In other words, if the export turnover in the numerator is to be arrived at after excluding certain expenses, the same should also be excluded in computing the export turnover as a component of total turnover in the denominator. The rea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e meaning given to the export turnover by the legislature is to be adopted while understanding the meaning of the total turnover, when the total turnover includes export turnover. If what is excluded in computing the export turnover is included while arriving at the total turnover, when the export turnover is a component of total turnover, such an interpretation would run counter to the legislativ ..... X X X X Extracts X X X X X X X X Extracts X X X X
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