Dismissing the appeal the Court held that section 80HHC of the Income-tax Act, 1961, contemplates three situations, viz., sub-section (3)(a) dealing with cases where the export is only of self-manufactured goods, sub-section (3)(b) dealing with cases where the export is only of trading goods, and sub-section (3)(c) dealing with cases where the export is of both self-manufactured goods as well as trading goods. Apart from this, the section nowhere deals with the situation of an assessee having more than one unit of business and one of the units being purely 100 per cent. export oriented unit and the other unit, a partially export unit. Even though the Act does not provide for dealing with such a situation, yet, being a beneficial provision, in the fitness of things, the assessee is entitled to the relief in respect of 100 per cent. export oriented unit. (AY.2002-03)