S.80HHC – DEPB credit falls under s. 28 (iiib) & DEPB premium falls under Section S.28(iiid)

HIGH COURT OF DELHI Date of Decision: 26th March, 2012. + ITA 1191/2011 PAL ENTERPRISES Vs.  CIT ORDER SANJIV KHANNA,J: (ORAL) Having heard counsel for the parties, we frame the following substantial question of law: “Whether the Income Tax Appellate Tribunal has erred in holding that duty entitlement pass book credit was cash assistance within the meaning of clause (iiib) to Section 28 of the Income Tax Act, 1961 and the entire amount including the premium received on transfer of DEPB was “profit” under clause (iiid) of Section 28 of the aforesaid Act and accordingly...