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TMI Blog2013 (1) TMI 139X X X X Extracts X X X X X X X X Extracts X X X X ..... ds till despatch. This cannot at all be termed to be a profit derived by the assessee from the export of such goods or merchandise coming within Section 80HHC. In favour of revenue - I.T.A.Nos.203 of 2000 & 210 of 2000 - - - Dated:- 24-7-2012 - MR. THOTTATHIL B.RADHAKRISHNAN MR. K. VINOD CHANDRAN JJ. APPELLANT: BY ADVS.SRI.A.K.JAYASANKAR NAMBIAR (SENIOR ADVOCATE) SRI. ANIL D. NAIR. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t interest income could not be included in the computation of income under Section 80HHC and confined the arguments to the rent on godown. The appellate Tribunal found the said issue also against the assessee. 2. While admitting the above appeals, this Court has raised the following two questions of law in both the appeals, which are identical: i) Whether on the facts and circumstances of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... spect to the eligibility of the godown rent received by the assessee to be treated as export profit for computing the relief under Section 80HHC. The assessee relied upon the decision of this Court in Mercantile and Marine Services v. CIT (233 ITR 257), to contend that godown rent paid by the assessee has to be held to be income eligible for deduction under Section 80HHC. The Tribunal rightly foun ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat proportion; the export turnover in respect of such goods bears to the total turnover of the business carried on by the assessee as applied to the total business profits of the assessee disclosed under the head "profits and gains of business or profession". The export profit to be taken into account is that derived by the assessee from the export of such goods or merchandise. The assessee's c ..... X X X X Extracts X X X X X X X X Extracts X X X X
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