In Brief
The Supreme Court considered whether the Madras High Court's dismissal of an appeal was correct under Section 80HHC of the Income Tax Act, 1961. The High Court had relied on Commissioner of Income-Tax v. P.R. Prabhakar (2005) 276 ITR 176 to dismiss the appeal. However, this Court had reversed that very decision in P.R. Prabhakar v. Commissioner of Income-Tax (2006) 6 SCC 86, clarifying that commission must be considered for calculating deductions under Section 80HHC. Consequently, the Supreme Court set aside the High Court's order and remanded the matter for fresh consideration on merits in light of the reversed precedent.
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