COMMISSIONER OF INCOME TAX vs WILLAMSON FINANCIAL SERVICES .

The Supreme Court addressed the timing of the Section 80HHC deduction under the Income-tax Act, 1961, determining that the deduction should be applied to the entire composite income from tea before the 60:40 apportionment mandated by Rule 8(1) of the Income-tax Rules, 1962. The Court held that the deduction is admissible against the total income derived from business, thereby reversing the Tribunal's decision which limited the deduction to 40% of the income. The ruling clarifies the interpretation of 'composite income' in relation to export profits.