DEPB sale proceeds cannot be broken down into “profits” and “face value”.

Title: – DEPB sale proceeds cannot be broken down into “profits” and “face value”. The entire amount is “profits” for the purpose of section 80HHC read with section 28(iiid) Brief : S. 28 (iiid) provides that “any profit on the transfer” of the DEPB shall be business profits. Under Explanation (baa) to s. 80HHC, 90% of “the sum referred to in s. 28(iiid)” has to be reduced from the business profits. Under the third Proviso to s. 80HHC (3), in the case of an assessee having an export turnover exceeding Rs. 10 crores, the profits referred to in s. 80HHC (3) can be incre...