In thepresentcase, the Assessee claims leasing business as one of the businesses of the Assesssee, but the Department challenges the claim of the Assessee that the leasing business was one of the businesses of the Assesssee, in the absence of any tangible evidence to carry out leasing business. we are of the opinion that though the lease rental income earned by the Assessee cannot be taxed as "income from other sources" under Section 56 of the Act, but the lease rent in the hands of the Assesee cannot be said to be income derived from export business of the Assessee. However, the definition ofClause (baa) under the Explanation toSection 80HHC,includes such other receipts by way of brokerage, commission, interest, rent, charges or any other receipt of a similar nature are included in such export profits to the extent of 10% by excluding 90% thereof by the deeming fiction viz., clause (baa) of the Explanation. We do not find any reason to deprive the Assesee before us in thepresentcaseof the said benefit to the extent of 10% by applying clause (baa) as quoted above. Therefore, to that exent only the aforesaid question is answered in favour of the Assessee and against Revenue.