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2. The brief facts of the case are as follows :-

The respondent/assessee in these cases is engaged in the business of exporting toys. The process of manufacture of the toys involves manufacture and then stickering job is performed, which involves three activities. The first activity involves "Tampoo Printing" with a power driven machine on the tyres and the letters "MRF" are imprinted in white colour. The second activity involves printing of "MRF" letters in various forms/designs on the boxes of the toys and the last activity is purchasing the stickers with the letters "MRF" and pasting the same on the boxes that contain the toys. In regard to the said activities, for the assessment years 2001-2002 and 2002-2003, the assessee claimed deduction under Section 80HHC on the income received for stickering the label 'MRF' on the toys. The assessing officer excluded the stickering income from business profits by invoking Explanation (baa) to Section 80HHC of the Income Tax Act. Aggrieved by the said order of the Assessing Officer, the assessee preferred appeals to the CIT (Appeals).