2. Export business — Deduction u/s.80HHC (prior to 1989) —
Deduction only to the extent it is covered by the reserve created for the said
reserve.
[Parekh Brothers v. CIT, (2009) 309 ITR 446 (SC)]
The Supreme Court dismissed the appeal from the decision of
the Kerala High Court to the effect that, where the reserve created for the
purpose of the special deduction u/s.80HHC of the Income-tax Act, 1961, is of
a lesser amount then deduction would be allowed only of the lesser sum
supported by the creation of the reserve.