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39.1 The learned AR alternatively contended that if such interest income is treated as income under the head other sources, then the assessee should be allowed for the deduction of the corresponding interest expenses.

40. On the other hand the learned DR supported the order of the authorities below.

41. We have heard the rival contentions of both the parties and perused the materials available on record. The provisions of section 10B of the Act provides that the exemption to the 100% EOU with respect to the profit derived by it from the export of articles or things or computer software. The manner for computing the profit eligible for exemption under this section has been provided under subsection (4) to section 10B of the Act. Under this subsection, the entire profit of the business of the undertaking is to be determined which is required to be apportioned in the ratio of export turnover to total turnover of the business in order to work out the profit derived from the export of the articles and things/computer software which is eligible for exemption under section 10B(1) of the Act. In other words, the provisions A.Y. 2008-09 of subsection (4) to section 10B of the Act refers to the profits of the business of the undertaking which implies that the entire profit of the undertaking is to be considered whether it was from the export activities or not. For example the income of the eligible undertaking such as rental, commission, interest, duty drawback shall also be considered for working out the exemption provided these income are part and parcel of business of the assessee. In holding so we draw support and guidance from the order of special bench of ITAT Indore in the case of Maral Oversea Ltd. vs. ACIT reported in (2012) 136 ITD 177 (Indore)(SB) wherein it was held as under: