with and subject to the provisions of this section, be allowed, in computing the total income of the assessee, a deduction from such profits ... narrower in scope than the expression "attributable to". In Sterling Foods (supra) it was held as under :--
"The source of import entitlements
against interest expenditure of Rs. 19,60,038/- while
computing the profits of business of the EOU.
5.1 In this connection, the AO referred ... allows the deduction of profits and gains derived
by the EOU in computing the total income. It was his case that the
income
fact that u/s 263 notice was issued that the loss
of Sterling Export and inclusion of interest on FDR in books and its
eligibility ... Book)
was in theAs regards the second unit in the
computation of name of Sterling Export, it is
income (page 2 explained from the side
assessee while computing the deduction admissible under
section 80-IC did not make adjustment of the losses suffered at Delhi. It has
computed the deduction ... case of Sona Koyo Sterling Systems Ltd. In that case, the issue
relates to computation of deduction admissible under section
case of
Pandian Chemicals 262 ITR 278, C.I.T. vs Sterling Foods 237 ITR 579.
8. On the other hand, ld. counsel ... case of Sterling Foods (supra). For the purpose of
section 80HHC the income derived from export is to be
computed as per the machinery provisions
complete code providing the mechanism for
computing "profits of the business" eligible for deduction under that
section which, in our submission ... Court, making a reference to its own decision in the case of Sterling
Foods: 237 ITR 579, held that duty drawback could not be held
Sterling Foods Vs. State of Karnataka AIR 1986 SC 1809 (SC).
2.7. Excess depreciation on a/c deference in Computation
Profits of the business" means the profits of the business as computed under the
head "Profits and gains of business or profession ... Supreme Court in the case of CIT Vs. Sterling Foods Ltd .
Reported at 237 ITR 579. Vide written explanation filed on 27.9.2004, it was stated
purpose of computing the deduction under that
section, the amount of income of that nature has to be computed in accordance with ... from the business of processing of bio degradable waste has to be
computed as per the provisions of the Act on standalone basis. He vehemently
purpose of computing the deduction under that
section, the amount of income of that nature has to be computed in accordance with ... from the business of processing of bio degradable waste has to be
computed as per the provisions of the Act on standalone basis. He vehemently
