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TMI Blog2012 (11) TMI 188X X X X Extracts X X X X X X X X Extracts X X X X ..... t. Ltd.) & Others Versus The Commissioner of Income Tax, Central-IV, Mumbai & Others2012 (2) TMI 101 - SUPREME COURT OF INDIA] - Held that:- Ninety per cent of not the gross interest/rent but only the net interest/rent, which has been included in the profits of the business of the assessee as computed under the heads ‘PGBP’ is to be deducted under clause (1) of Explanation (baa) to Section 80HHC f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... partment to reduce 90% of the net commission received by the assessee from the profits of the business for computation of deduction under Section 80HHF of the Income Tax Act, 1961?" At the relevant time, a group of matters on the interpretation of Section 80HHC of the Income Tax Act, 1961, was pending in this Court in the case of Topman Exports v. CIT as well as in the case of ACG Associated Cap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Department, there is a difference between these two sections and their respective applicability. 5. Under the above circumstances, we request the High Court to decide the above question in accordance with law expeditiously, if possible, within a period of three months from today. The High Court may also consider in that light the judgement of this Court in ACG Associated Capsules (P.) Ltd. (supr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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