- (1.) Heard Learned Counsel on both sides. The transferred case is disposed of as withdrawn.
(2.) Heard Learned Counsel on both sides.
(3.) The question which requires to be answered in this case is as follows: Whether, on the facts and circumstances of this case and in law, the Income Tax Appellate Tribunal was correct in directing the Department to reduce 90% of the net commission received by the Assessee from the profits of the business for computation of deduction under Section 80HHF of the Income-tax Act, 1961 At the relevant time, a group of matters on the interpretation of Section 80HHC of the Income-tax Act, 1961, was pending in this Court in the case of Topman Exports v. CIT, 2012 205 Taxman 119 as well as in the case of M/s. ACG Associated Capsules (P.) Ltd. v. CIT, 2012 205 Taxman 136. Later on, Topman Exports , and M/s. ACG Associated Capsules (P.) Ltd. , were decided on 8th February, 2012. One of the points which the Department raised was that the provisions of Section 80HHF of the Act may not be identical to the provisions of Section 80HHC of the Act. Consequently, this case was de-tagged.;