The Tribunal for the assessment year 2011-12 had treated the interest income as part of business receipts earned by the assessee on the basis that all profits and gains including incidental income of an export oriented unit even in the nature of interest on bank deposits or soft loans would be entitled for deduction under section 10A or 10B of the Act. The Assessing Officer was to grant deduction under section 10A of the Act in respect of interest income earned on fixed deposits. Followed CIT v. Hewlett Packard Global Soft Ltd. [2018 403 ITR 453 (Karn) [FB and Cybertech Systems And Software Ltd. v. DCIT [2018 91 taxmann.com 407 (Bom) (HC).

The Tribunal in the assessee’s own case for the assessment year 2011-12 had held that the deduction was available on the profits derived by the assessee on the entire profits and gains derived by the undertaking engaged in the business of export of articles or things. Hence the assessee was entitled for deduction under section 10A of the Act in respect of the sums in question. Followed CIT v. Motorola India Electronics Pvt. Ltd. [2014 2 ITR-OL 499 (Karn)(HC).(AY. 2009-10)