PAL ENTERPRISES Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) Having heard counsel for the parties, we frame the following substantial question of law :

(2.) The DEPB was transferred by the assessee to others and profit of Rs. 20,75,382/- was earned by way of premium.

(3.) The assessee had claimed deduction of Rs. 2,77,48,947/- under Section 80HHC of the Income Tax Act, 1961 ("Act", for short) after accounting for these export incentives and other income.