Court held that ; if rent or interest is a receipt chargeable as profits and gains of business and chargeable to tax under S. 28, and if any quantum of rent or interest of assessee is allowable as an expense in accordance with S. 30 to 44D and is not to be included in profit of business of assessee as computed under head ‘Profits and gains of business or profession’, ninety per cent of such quantum of receipt of rent or interest will not be deducted under clause (a) of Explanation (baa) to section 80HHC.Followed ACG Associated Capsules (P) Ltd v. CIT (2012) 343 ITR 89 (SC)
Chambal Fertilizers & Chemicals Ltd v. CIT (2018) 95 taxmann.com 313 ( Raj) (HC) Editorial: SLP of revenue is dismissed ,CIT v. Chambal Fertilizers & Chemicals Ltd. (2018) 257 Taxman 93 (SC)
S. 80HHC : Export business – Profits and gains of business or profession- Rent -Interest – Ninety per cent of such quantum of receipt of rent or interest will not be deducted under clause (a) of Explanation (baa) to section 80HHC . [ S.28 , 30 to 44AD ]