The claim of the assessee to deduction under section 80HHC was confined only to sale to the export house. The export house had issued disclaimer certificate along with copy of the revised chartered accountant certificate. The export house had not claimed deduction under section 80HHC with regard to export of goods manufactured by the assessee. Therefore, the assessee was entitled to deduction under section 80HHC with regard to goods sold to the export house. However, deduction under section 80HHC claimed by the assessee on account of sale to export house was Rs. 1,67,23,392 which was in excess of the profits earned by the export house. Therefore, for the limited purpose of quantification of deduction under section 80HHC the issue was restored to the Assessing Officer. (AY. 2002-2003)