application for PAN, TAN in the partnership deed of the firm, import-export
code issued by DGFT etc. in this regard the copy of said
pages 32-37 of the Paper Book and the details regarding importer
exporter code of the creditors are available on pages
partnership deed dated
01.04.08 as well as its certificate of exporter/Importer code (IEC)
bearing No.0493014233 issued on 13.09.1993.
3. In reply, the Revenue ... shoe' company. It has been issued
certificate of exporter/importer code as well(supra). For A.Y.2005-06,
the assessee had filed
that assessee must be in the business of export and
secondly that sale proceeds of such exports should be receivable in India in
convertible foreign exchange ... assessment year
2001-02 exporters would not get 100% deduction in respect of profits derived
from exports but that they would get deduction
further held that
Ss. 80-IB/80-IA are a Code by themselves as they contain both substantive as
well as procedural provisions ... neutralize the incidence of customs duty
payment on the import content of export product DEPB credit/duty drawback
receipt do not come within the first
Suresh Nanda, New Delhi vs Department Of Income Tax
Page 1 of 91
IN THE
mentioned at point
no.3, the assessee company has been manufacturing CPC blue
since, the year of its incorporation & it was a sole manufacturing ... business as manufacturers, formulators,
processors, producers, makers, buyers, sellers, re-sellers,
importers, exporters, distributors, suppliers, fermentations,
distillers, refiners, stockiest, agents, merchants,
developers, consultants and dealers
profit or the premium, is
not export profit Since it does not arise out of export activity or import
20
activity and arises because ... only to neutralize the incidence of custom duty. On the
import content of the exports. We have examined the format of DEPB
Scheme and come
80HHC is
whether the assessee is carrying on business of exclusive export or exports
and domestic business also. If it is the former, clause ... proportion the export turnover bears
to the total turnover to arrive at the profits derived from the export of goods or
merchandise. Section 80AB postulates
profit or the
premium, is not export profit Since it does not arise out of export
activity or import activity and arises because of trading ... only to neutralize the incidence of
custom duty. On the import content of the exports. We have
6
examined the format of DEPB Scheme