2012 (9) TMI 401

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..... has, by the said activity, earned profits. It is clear that the assessee had never claimed the aforesaid income as income entitled to deduction under Section 80HHD and the only effect of that was to treat it as part of the profits of the business so that this component is included in the profits of business in the formula provided under Section 80HHD for the purpose of calculating deduction un .....

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..... ich is available for the earning of foreign exchange from providing services to the foreign tourists as prescribed in the said Section, whereas the assessee company included the foreign exchange encashed by it as money changer licensee in the total foreign exchange earning. 2. The CIT (A), however, allowed this claim only in respect of commission receipt of ₹ 8,75,603/- from M/s LKP Mercha .....

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..... only effect of that was to treat it as part of the profits of the business so that this component is included in the profits of business in the formula provided under Section 80HHD of the Act for the purpose of calculating deduction under the said provision which provides as under:- Profit of business x Foreign exchange receipts over total receipts of business 4. In view of this clarificatio .....

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