Per Dr. O.K. Narayanan, A.M. - This appeal relating to the assessment year 1993-94 is filed at the instance of the Revenue. The appeal is filed against the order of the CIT(A), Kochi, dated 15-10-1997 and arises out of the regular assessment completed under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as the Act).

2. The respondent-assessee is a company engaged in the business of manufacturing spices products, such as oleoresins, essence and other items and exporting them to outside India. The assessee-company also supplies such manufactured products to other companies on a job work basis. The assessee belongs to the Synthite Group of Companies, who are one of the largest exporters of spices products in the country. It is also said that the assessee has received certificate of Honour from the Spices Board for its export performance and holds the quality assurance mark of ISO 9002.

3. As the assessee is an exporter of spices products as stated above, it has been claiming the benefits available under section 80HHC of the Act on a regular basis from year to year. The claim of the assessee has been consistently accepted and allowed by the Department. For the i