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10. We must however, notice an argument advanced by the learned Departmental Representative based on the judgment of the Supreme Court in the case of Hindustan Lever Ltd. v. CIT . In that case, the assessee made profits on sale of export entitlements and claimed deduction under Section 80HHC in respect of such profits. The Supreme Court held that the profits cannot be said to have been derived from the export of goods out of India as required by the section. It was held that the immediate source of the profits was the sale of the import entitlements and not the export activities. Firstly, the Supreme Court was not concerned with the DEPB and DFRC receipts. We have already referred the Import Export Policy and Procedure 1997-2002. Both the incentives are provided to the assessee only because of the exports. To repeat, DFRC is issued to an exporter for the import of inputs used in the manufacture of goods without payment of basic customs duty and special additional duty. However, such inputs would be subject to the payment of additional customs duty equal to the excise duty at the time of import. There are other conditions attached to the issue of the certificate. Firstly, the DFRC shall be issued only in respect of export products covered under the provisions as notified by DGFT. Secondly, the certificate shall be issued for import of inputs having the same quality, technical characteristics and specification as those used in the end-product and as indicated in the shipping bills. Thirdly, the certificate shall be subject to minimum value addition of 33 per cent. Fourthly, the certificate may be issued in respect of exports for which payments are received in non-convertible currency. The DEPB is issued as an optional facility for exporters who do not wish to go through the licensing route. The objects of the DEPB scheme 'is to neutralize incidence of customs duty on the import content of the export product. The neutralization shall be provided by way of grant of duty credit, against the export product'. The credit is given as a percentage of the FOB value of exports made in freely convertible currency. The credit is available against export products and at such rates as may be specified by way of public notice, for import of raw material, intermediates, components, etc. The DEPB is freely transferable subject to the condition that it shall be for import at the port specified by the DEPB, which shall be the port from where exports have been made.