P.R. PRABHAKAR vs COMMNR. OF INCOME TAX, COIMBATORE

The Supreme Court addressed the applicability of Section 80HHC of the Income Tax Act, 1961, concerning the entitlement to deductions for export profits. The Court held that income derived from commission for procuring export contracts is not eligible for exemption under Section 80HHC if the export business incurs a loss, as clarified by the amendment effective from 1.4.1992. The Court upheld the High Court's ruling that the amendment was clarificatory and had retrospective effect, thereby affirming the decision in favor of the Revenue.