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TMI BlogDeduction under section 80HHC of the Income-tax Act, 1961, as amended by the Finance Act, 1990--Clarification regardingX X X X Extracts X X X X X X X X Extracts X X X X ..... 1990 (See [1990] 184 ITR (St.) 137, explaining the deduction admissible under section 80HHC of the Income-tax Act, 1961, in respect of export profits. 2. In paragraph 5 of the aforesaid circular, it has been stated that the Finance Act, 1990, has amended section 28 of the Income-tax Act, by inserting therein clauses (iiia), (iiib) and (iiic) with retrospective effect with a view to ensuring that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ains of business or profession" with effect from 1-4-1967. The duty drawback has been so included with effect from 1-4-72. The profits on sale of import entitlement licences have been included with effect from 1-4-1962, the date from which the Income-tax Act, 1961, came into force. 4. The Department's view all along has been that these export incentives are revenue receipts and hence taxable. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ndment referred to above has been made with effect from 1-4-1991. Since the amendment only clarifies the legislative intention as it always existed, the position as regards the past years would be the same as that after coming into force of the amendment. In other words, the meaning of the term "total turnover" for the assessment year 1990-91 and earlier years, when the law did not contain any def ..... X X X X Extracts X X X X X X X X Extracts X X X X
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