Ingersoll-Rand (India) Ltd v .CIT (2020) 427 ITR 158 /192 DTR 369(Karn)(HC)

S.80HHC: Export business – Explanation (baa) applicable only to receipts similar to brokerage, commission, interest, rent or charges

Court held that  the Commissioner (Appeals) as well as the Tribunal had reduced 90 per cent. of Rs. 3,05,11,720 being income from services rendered and Rs. 21,77,493 being sundry income from profits of business while computing deduction under section 80HHC . The service charges could not be deducted as profits of business means profits of business reduced by 90 per cent. of any sum referred to in clauses (iiia), (iiib), (iiic), (iiid) and (iiie) of section 28 or of any receipts by way of brokerage, commission, interest, rent, charges or any other receipt of a similar nature included in such profits. ( AY.2000-01, 2001-02, 2002-03)