B. DESRAJ vs C.I.T., SALEM

The Supreme Court held that the amounts received by the appellant as Duty Drawback and Cash Compensatory Allowance during the accounting year ending 31st March, 1991 are eligible for deduction under Section 80HHC(3) of the Income Tax Act, 1961, despite no exports being made in the assessment year 1991-92. The Court emphasized that these amounts were related to exports made in the previous year, thus qualifying as business profits under the relevant provisions. The ruling upheld the Tribunal's decision, allowing the deduction claimed by the appellant.