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Section 80HHC of Income-tax Act, 1961 - Deductions - Exporters Negative export profits should not be ignored when aggregating total turnover including other export [Assessment year 1992-93] [In favour of revenue] CIT v. Welcast Steel Ltd. [2009] 314 ITR 36 (Kar.) In view of the s of the Supreme Court in the case of IPCA Laboratory Ltd. v. Dy. CIT[2004] 266 ITR 521 and in the case of A. M. Moosa v. CIT [2007] 294 ITR1, negative export profits should not be ignored when aggregating the total turnover including other export. M.V. Seshachala for the Appellant. S. Parthasarathi and Raviraj for the Respondent. JUDGMENT Deepak Verma, J. - Heard Sri M. V. Seshachala, learned counsel for the appellants and Sri S. Parthasarathi, learned counsel for the respondent. 2. This appeal is at the instance of the Revenue under section 260A of the Income-tax Act, 1961, against the order passed by the Income-tax Appellate Tribunal on March 21, 2003, in I. T. A. No. 226/Bang/1998. The following substantial question of law has been formulated in this appeal. "Whether the Tribunal was correct in holding that the negative export profits should be ignored when aggregating the total turnover including other export by not taking into consideration the specific definition adduced in section 80HHC read with section 80AB of the Act for the purpose of computing deduction under section 80HHC of the Act ?" 3. The question that has been formulated in the said appeal stands answered by two s of the Supreme Court in the cases of IPCA Laboratory Ltd. v. Deputy CIT [2004] 266 ITR 521 and in the case of A.M. Moosa v. CIT [2007] 294 ITR 1. 4. The Supreme Court in the case of A.M. Moosa v. CIT [2007] 294 ITR 1, while considering the meaning of the word "profit", has made the following observations (headnote) : "The word 'profit' in section 80HHC(l) and (3) of the Income-tax Act, 1961, means a positive profit. A plain…

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