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16. But even if we were to agree with Mr. Shah that the profits and gains on the export should have been worked out or computed in the manner provided in sub-r. (3), the material which is produced by the assessee-company is not sufficient or adequate to work out such profits and gains in the manner provided under the said sub-r. (3). There is absolutely no material on record to show what goods were the subject-mater of direct export sales by the assessee-company. It is true that in the question which is framed by the Tribunal in each of the references, it is mentioned that deduction under s. 2(5)(a)(i) was claimed on account of the export of cloth out of India; but there is no finding recorded by the Tribunal that it was cloth alone which was exported out of India by the assessee-company. The record also does not disclose as to what were the different varieties of cloth which were exported by the assessee-company out of India. It is likely that only certain items out of various products manufactured by the assessee-company were exported. The assessee-company manufactures and sells ready made garments also. There is no material on record to show whether what was exported was ready-made garments or cloth. Therefore, unless it is shown which were the products which formed part of the export business, it would be difficult to work on profits and gains on export under sub-r. (3). The key words in working out profits and gains under sub-r. (3) are : "the amount which bears to the profits and gains of the whole business of which such exports form a part" . Therefore, for the purpose of computation of the profits and gains under sub-r. (3) only that business of which export forms a part is relevant. The argument advanced by counsel for the assessee that the expression "whole business" is capable of being interpreted as the entire business inclusive of export as also non-export business (manufacturing and trading activities in its entire business within India) has merely to be stated to be rejected. The basic idea is to encourage exports and offer incentives, provided the exports result in profits. One cannot be oblivious to this basic design. How can "profits from exports" be ever derived by reference to profits from non-export business ? One can conceive of profits in export business in respect of a company which incurs overall loss in non-export business or entire business. It would be taxing one's commonsense to place an interpretation which would countenance drawing an inference that the export business resulted in a profit if the non-export business resulted in profit or that by any rational process one can guess at the profits from the export business as bearing any percentage of the non-export profit. We, therefore, have no hesitation in repelling the specious plea. Therefore, unless we know what goods are exported, it would be difficult to ascertain the "whole business" of which such export forms part of the purpose of sub-r. (3). We are not examining this aspect of the matter in detail but only indicating that even if sub-r. (3) were attracted, there is no material on record on the basis of which a computation of profits and gains of export could be made under the said sub-r. (3). We are not examining this aspect in detail for the obvious reason that the assessee-company has failed to make out a case for the application of sub-r. (3). The assessee-company has not placed on record the relevant facts to prove whether or not it had derived profits and gains from the export of goods, and if so, what is the extent of such profits and gains. What in reality and substance it is arguing is that the Revenue authorities and the Tribunal should investigate the facts and give it relief of the rebate as claimed by it. In this connection we agree with the following observations made by the Allahabad High Court in L.H. Sugar Factories & Oil Mills v. CIT [1980] 124 ITR 58 (p. 67) :