Commr.Of Income Tax-Iv, Tamil Nadu vs B.Suresh

The Bombay High Court held that the assessee is entitled to deduction under Section 80HHC of the Income Tax Act for earnings from the export of films, interpreting 'goods' and 'merchandise' broadly to include films as articles of trade. The Court emphasized that the term 'sale' encompasses leases, as supported by Rule 9A(7) and Rule 9B(6), which recognize the lease of rights for exhibition as qualifying for deductions. The appeal by the Department was dismissed, affirming the Tribunal's decision in favor of the assessee.