1. This appeal is directed against the order of the Income-tax Appellate Tribunal, Jodhpur Bench, Jodhpur, dated December 17, 1999, in two cross-appeals arising out of assessment proceedings for the assessment year 1989-90. The substantial question of law framed at the time of admitting the appeal reads as under :

" Whether, on the facts and circumstances of the case, the Tribunal has correctly construed the provisions of section 80HHC, in the matter of computing profits and gains of their business, in the context of the said provision for granting deduction ?"

2. One of the assessee' s business in which the assessee is engaged in the business of export out of India of goods and merchandise to which section 80HHC applies.

3. In the first instance, on October 31, 1989, the assessee had submitted a return of income declaring loss computed in accordance with the provisions of the Act at Rs. 62,63,970. The assessee filed a revised return for treating the cash compensatory support received during the year at Rs.75,91,462 as income from business of export on account of amendment in the Act of 1961 by inserting clauses (iiia), (iiib) and (iiic) in section 28 of the Act. These amendm