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(aa) "export out of India" shall not include any transaction by way of sale or otherwise, in a shop, emporium or any other establishment situate in India, not involving clearance at any customs station as defined in the Customs Act, 1962 (52 of 1962);
(b) "export turnover" means the sale proceeds, received in, or brought into, India by the assessee in convertible foreign exchange in accordance with Clause (a) of Sub-section (2) of any goods or merchandise to which this section applies and which are exported out of India, but does not include freight or insurance attributable to the transport of the goods or merchandise beyond the customs station as defined in the Customs Act, 1962 (52 of 1962);
(ba) "total turnover" shall not include freight or insurance attributable to the transport of the goods or merchandise beyond the customs station as defined in the Customs Act, 1962 (52 of 1962): .

Provided that in relation to any assessment year commencing on or after 1st April, 1991, the expression "total turnover" shall have effect as if it also excluded any sum referred to in Clauses (iiia), (iiib) and (iiic) of Section 28;

(baa) "profits of the business" means the profits of the business as computed under the head "Profits and gains of business or profession" as reduced by-

8. Let us first understand what is the meaning given to the term 'export turnover' and 'total turnover' under the Act. As extracted above the term "export turnover" is defined in Expln. (b) to Section 80HHC(4A) to mean that the sales proceeds received in, or brought into, India by the assessee in convertible foreign exchange on the export of goods outside India but does not include freight or insurance attributable to the transport of goods or merchandise beyond the customs station as defined in the Customs Act, 1962 (hereinafter referred to as "Customs Act"). Under Expln. (ba) "total turnover" is defined not to include freight or insurance attributable to the transport of the goods or merchandise beyond the customs station as defined in the Customs Act, 1962. The expression "total turnover" also excluded any sum of export incentives referred to in els. (iiia); (nib) and (iiic) of Section 28. It is thus evident that though 'export turnover' is stated to be the sales proceeds received in convertible foreign exchange without inclusion of freight and insurance, 'total turnover' is not given any meaning but negatively stated to be not including freight and insurance and also receipts of export benefits. The legislature while specifically excluding freight or insurance attributable to foreign transport of goods did not consciously exclude excise duty and sales-tax received by the assessee from the customers. In other words, the total turnover is the gross amount of turnover of the business as reduced by transport and insurance attributable to transport of goods beyond the customs station and the receipts of export incentives. Revenue's contention is that when particular items alone are excluded, the general meaning excluding only those specified enumerated receipts should be given to the term.