BHARATH SEA FOODS Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THE following question is to be answered :

(2.) THE question that is posed, it is obvious, relates to the qualification for deduction under S. 80HH of the IT Act, 1961 with regard to the income received by the assessee from sale of import entitlement. The Tribunal in its order dt. 12th Jan., 1987 has also considered the question and in that connection has referred to its earlier order dt. 14th Nov., 1985 in ITA Nos. 495 and 496 (Coch) 1983 in the matter of Shri A.M. Moosa for the asst. yrs. 1976-77 and 1977-78. In that matter also the question was whether the assessee Moosa was entitled to the benefits of S. 80HH with regard to income received from the sale of import entitlements.