Dismissing the appeal the Court held that the Tribunal was right in holding, on findings of fact, that since the assessee had failed to establish beyond doubt that the interest earned on the deposit or advance was income from the export business the benefit of deduction as per computation provided in clause (baa) of the Explanation to section 80HHC of the Income-tax Act, 1961 could not be extended to the assessee. No substantial question of law.