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TMI Blog1992 (1) TMI 76X X X X Extracts X X X X X X X X Extracts X X X X ..... anufacture and export of Isabgol and export and import of edible oil. The assessee had exported Isabgol products to foreign countries through commission agents. In the course of income-tax assessment for the assessment years 1978-79, 1979-80 and 1980-81, the assessee had claimed export markets development allowance or in other words, weighted deduction under section 35B of the Income-tax Act, 1961 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y way of payment of interest to the bank on the said advances which were taken for purchasing raw materials, it was entitled to weighted deduction under section 35B of the Act. According to the assessee, this expenditure was incurred in connection with its export business and, therefore, it was entitled to weighted deduction under clause (b) of section 35B(1) of the Act. The Income-tax Officer, ho ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e is entitled to deduction under section 35B in respect of the interest paid to the bank on packing credit ?" The expenditure which the assessee had incurred in making payment of interest to the bank on its packing credit account would not fall under sub-clause(iii) of clause (b) of section 35B(1). The assessee had taken loans or advances from the bank for purchase of raw materials to manufactur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y mention that the Tribunal has not stated the details of the interest paid to the bank. All that is stated is that interest was paid on what is described as "packing credit". What is meant by "packing credit" is also not explained by the Tribunal. We have, however, assumed that, as in similar other cases, the assessee must have taken loans and advances from the bank for purchasing raw materials t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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