Court : Income Tax Appellate Tribunal ITAT Pune
Decided on : Jul-14-1997
Reported in : (1998)64ITD396(Pune.)
..... of the assessee-company did not want to be involved in the business of exports on account of stringent provisions of the foreign exchange regulation act. the claim under section 80hhc, in our opinion, is the consequence of the decision of the male directors to carry on separate business in partnership and not the ..... to 20 to 25 bags. in the course of hearing, the bench had repeatedly asked the learned counsel for the assessee whether there was any comparable case claiming such higher percentage of loss in bardana, but he could not point out any such case. however, it was submitted by him that ..... packing. he relied on the decision of supreme court in the case eastern paper industries 43 elt 201 and the decision of the rajasthan high court  elt 6 wherein it has been held that primary packing is part of direct cost. he also refuted the contention of mr.khandelwal by submitting ..... itself. once the profits are determined, then such profits are further to be computed as provided in section 29. profits on sale can be arrived at only after deducting the corresponding expenditure in respect of such sales. therefore, in our opinion, all the expenditure which are necessary in making the final product ..... to claim exemption under section 10b. on the contrary, separate business has been started with a meagre capital without any effort. he further pointed out that the profits of the firm have also been enjoyed by the assessee-company as there was free flow of funds. a chart has been furnished by .....Tag this Judgment!