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we hold that the Assessee is not entitled for any deduction under Section 80HHC (1A) of the Act for any of the Assessment Years in question before us, for want of compliance with the mandatory conditions prescribed under Section 80HHC (1A) read with Sub-section (4A) and in respect of FOB value of export made by it on behalf of Export Houses as well as in respect of Export Premium received by it during these years and the question of resort to Section 147/148 of the Act for Reassessment is, therefore, academic and left unanswered.

Shanti Prime Publication Pvt. Ltd.

Sec. 80HHC of Income Tax Act, 1961—Special Deduction—Assessee is not entitled for any deduction under Section 80HHC (1A) for want of compliance with the mandatory conditions prescribed under Section 80HHC (1A) read with Sub-section (4A) and in respect of FOB value of export made by it on behalf of Export Houses as well as in respect of Export Premium received by it—PARWAZ FOOD PACKET (PFP) Vs. DEPUTY CIT [2020] 421 ITR 377 (MAD)

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