Whether quota sale receipt covered U/s. Sections 28(iiia) to 28(iiie) or S. 28(iv)

Whether the amount received by the Assessee from the sale of quota for export of goods could be equated with income mentioned in Sections 28 (iiia) to 28 (iiie) or Section 28 (iv) of the Income Tax Act, 1961 so as to be eligible for a deduction under Section 80HHC of the Act.”  In the said assessment year, the assessee had earned premium of Rs.12,26,140/- on sale of export quota. The Assessing Officer held that this premium is covered by Section 28 (iiia/b/c) and accordingly computed deduction under Section 80HHC but without giving benefit of provisos under sub Section (3) to Section 80HHC....