JUDGMENT

Rohinton Fali Nariman, J. - Civil Appeal Nos. 4590, 4591, 4592 and 4603 of 2018:

1. This batch of appeals arises from a judgment passed by the High Court of Punjab and Haryana at Chandigarh in which the Appeals preferred by the Revenue have been dismissed relying upon Commissioner of Income Tax, Thiruvananthapuram vs. Baby Marine Exports, Kollam (2007) 4 SCC 555 in order to arrive at a conclusion that the supporting manufacturer is at par with the actual direct exporter of goods when it comes to deductions that are available Under Section 80HHC of the Income Tax Act, 1961 (in short 'the Act').

2. It is unnecessary to go into the facts of each of these cases as it is undisputed that the Assessee in each of these cases is a supporting manufacturer. The scheme insofar as Section 80HHC of the Act is concerned is crystal clear. The marginal note to Section 80HHC reads-Deduction in respect of profits retained for export business.

80HHC. (1) Where an Assessee, being an Indian company or a person (other than a company) resident in India, is engaged in the business of export out of India of any goods or merchandise to which this Section applies, there shall, in accordance with and