Allowing the appeal of the aasessee the Court held that the assessee was entitled to take only the net amount of the sale value of the duty entitlement pass book credit after deducting the face value for the purpose of section 80HHC of the Income-tax Act, 1961 while applying Explanation (baa) of the provision. Duty entitlement pass book credit is chargeable as income u/s 28(iiid) of the Act. Followed Topman Export v. CIT ( 2012) 342 ITR 49 (SC) (AY. 2003 -04)
Gold Line Exports v. ITO (2019) 412 ITR 465 (Mad.)(HC)
S. 80HHC : Export business–Duty entitlement pass book credit- Entitled to take only net amount of sale value after deducting face value. [S.28(iiid)].