P.R. Prabhakar vs Commissioner Of Income Tax, Coimbatore

The Supreme Court addressed the applicability of Section 80HHC of the Income Tax Act, 1961, regarding deductions for export profits. The Court held that income derived from commission for procuring export contracts does not qualify for exemption under Section 80HHC if the export business incurs a loss, as clarified by the Central Board of Direct Taxes (CBDT) circulars. The High Court's ruling that the amendment to Section 80HHC had retrospective effect was upheld, leading to a negative answer to the questions referred by the Income Tax Appellate Tribunal.