West Coast Paper Mills Ltd v. ACIT [2024] 164 taxmann.com 712 (Bom.)(HC)

S. 80HHC: Export business-Computation of deduction-Turn over-Scrap sale-For purpose of section 80HHC, proceeds of sale of scrap would not form part of total turnover.[S.260A]

For the purpose of computing the deduction under section 80HHC, the High Court held that proceeds from the sale of scrap must be excluded from ‘total turnover’. Relying on the Supreme Court’s judgment in CIT v. Punjab Stainless Steel Industries [2014] 364 ITR 144 (SC), the Court clarified that the term ‘total turnover’ in the statutory formula refers to the turnover from the assessee’s principal business activity-in this case, manufactured paper and not ancillary receipts such as those from scrap sales. (AY. 1997-98)

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