This is appeal by revenue, directed against order of CIT (Appeals)-XI, Ahmedabad dated 24-3-1998, and relevant assessment year is 1994-95. 2. appeal involves two issues, both of which relate to computation of deduction exigible under section 80HHC of Income-tax Act, 1961 (hereinafter referred to as "the Act"). 3.1 first ground of appeal is deletion of amount of Central Excise and Sales-tax, from amount of "total turnover", and which stood included therein, by Assessing Officer, on basis that they form part of domestic turnover of assessee, and which in turn, forms part of its "total turnover". 3.2 learned AR relied on judgment of Hon'ble Bombay High Court in case of CIT v. Sudarshan Chemicals Industries Ltd. [2000] . 3.3 learned DR could not bring any contrary decision to our notice. 3.4-1 In fact, decision of Calcutta Bench was taken by revenue before jurisdictional High Court, which has upheld same CIT v. Cloride India Ltd. [2002] , expressed its agreement therewith. As such, matter should be taken as judicially settled. 3.4-2 It may be pertinent here to state that decision of Apex Court in Chowringhee Sales Bureau (P.) Ltd. v. CIT [1973] 87 ITR 542, and Sinclair Murray & Co. (P.) Ltd. v. CIT [1974] , reliance on which had been placed by Assessing Officer in arriving at his decision, have been specifically considered, amongst others, by different High Courts, and before them, by Tribunal, orders of which were confirmed by them. Courts have, uniformly, been guided, in deciding matter, by consideration of construing words "total turnover" in purposive, contextual and harmonious manner, so as to effectuate object and intent of section 80HHC, in which they appear, and which is separate code in itself for grant of deduction in respect of profits attributable to export turnover of assessee. And do not, in any manner, detract from general ratio of decisions of Supreme Court (supra) rendered in context of general definition or meaning of word "turnover", i.e. that "levies" under sales tax and excise duty are received by seller, in his capacity as trader, and under contract of sale. 3.5 Respectfully following above decisions(s), we direct Assessing Officer to exclude amount of central excise and sales-tax, as included by him in calculation of total turnover, for purpose of its computation under section 80HHC. 4. second ground of appeal relates to treatment of following amounts, for purpose of computation of deduction under section 80HHC: (a)Central Excise Set-off, (b)Sales Tax Set-off, (c)Income-tax Refund; (d)Profit on sale of assets. 4.1 Assessing Officer had excluded these amounts from computation of "Profits of business" with reference to Explanation (baa) to section 80HHC, while CIT(A) directed him not to do so, on ground that first two are derived from export business, and latter two do not form part of income subject to tax in first place, so that question of their exclusion therefrom does not arise. We shall consider each of items separately. 4.2 Central Excise set-off, as also discussed at length by CIT(A) in his order, and also by learned AR before us, is credit received in respect of excise duty suffered on raw-material consumed for manufacture of goods exported out of India. learned DR, who also happened to be Assessing Officer in this case, however, contended that these are only receipts that fall in category of rent, commission, brokerage, etc. and thus, would need to be excluded (to extent of 90% thereof) in terms of second limb of Explanation (baa) to section. 4.3 We are not persuaded by stand of learned DR, and correspondingly, are impressed by claim of appellant. Central Excise set-off is only abatement in cost of goods exported, to extent of excise duty suffered thereon, as exports are free from all such levies. same is, in fact, paid in first instance only as it would, otherwise, be cumbersome and tedious for Government (in concerned Department), to keep track of all such goods removed without payment of duty, and simultaneously, to place onus and risk of claim for exemption of duty on beneficiary, i.e., exporter, who would discharge it through requisite documents evidencing export, as also payment of duty thereon. This, as we understand, is raison de'tre of Customs and Excise Duties Draw Back Rules. fact that credit in respect of such duty is granted not in cash, but by exemption of duty payable on domestic clearances, is to our mind, immaterial to our purpose, i.e., to ascertain its nature. 4.4 We, therefore, are of view that Central Excise set-off is in nature of export incentive and its receipt directly relatable to export activity. 4.5 next question, however, that needs to be addressed is, whether it i s sum referred to section 28(iiic) or not, for its treatment, and therefore, quantum of deduction under section 80HHC, would be influenced thereby. appellant, before Assessing Officer, expressed its acceptance of nature of amount as one described under section 28(iiic). Assessing Officer, however, was of view that it is not case, as it was not received in pursuance to Duty Draw Back Rules. CIT(A), before whom assessee had also pleaded likewise, in alternative, did not find it necessary to consider this aspect of matter, as in his opinion, assessee succeeded on its first plea itself, that is, that it was receipt directly relatable to exports, and therefore, not required to be reduced under Explanation (baa). 4.6 Admittedly, there is no dispute or difference as to nature of receipt/credit, or its quantum. That being so, credit in respect of excise duty on inputs consumed for export sales, against domestic (excisable) sales (clearances) would also be through prescribed procedure, and not otherwise. Even as both appellant, as well as Assessing Officer, have not placed any material on record to refurbish their respective claims, fact of matter is that, such credit, which is essentially only refund (draw-back) of duty already collected, on being shown to have been so, in excess of that leviable (being in respect of exports sales), cannot, but be in terms of standardized rules framed in this regard under principal or delegated legislation. Central Excise set- off, being of same species as Custom and Excise duty draw-back covered under section 28(iiic), and which is to be excluded (to extent of 90 per cent thereof) under Explanation (baa), we are of view that it shall have to be similarly reduced, treating it as covered within ambit of section 28(iiic). Consequently, said amount would also be required to be added back proportionately under proviso to sub-section (3) of section 80HHC. 5. next credit is Sales tax set-off. nature of amount, and incidents attached therewith, are same as to that of Central Excise set- off, only difference being that levy is under different statue. We find no reason to deviate from view expressed in respect of Central Excise set-off, except that amount obviously not falling under section 28(iiic), would not be required to be excluded at all in terms of Explanation (baa). Needless to say, question of its subsequent add-back does not arise. 6.1 other two sums credited by assessee to its Profit & Loss account, and under challenge, are "Income-tax refund" (Rs. 58,418) and "profit on sales of Assets" (Rs. 3,862). There is, apparently, no disagreement as to nature of said amounts, but only of their treatment, in computation of deduction exigible under section 80HHC. Both sums do not, as contended before us by learned AR, as also earlier before lower authorities, do not form part of "Profit and Gains from Business or Profession (PGBP)", from which amount of "Profits of Business" is to be derived by effecting some reductions (Explanation (baa) so that question of their further deduction under Explanation (baa) does not, and only understandably, arise. 6.2 learned DR could not advance any argument in favour of stand o f Assessing Officer, who has accorded uniform treatment to all amounts included under head "Miscellaneous Income (MI)", of which impugned amounts purportedly form part, without considering its composition, perhaps inadvertently, and which is not discussed by him in his order. Accordingly, we uphold decision of CIT(A), and direct Assessing Officer to ignore said amounts for purpose of section 80HHC, being already reduced in arriving at figure of PGBP, after satisfying himself as to correctness of assessee's claim as regards inclusion of these sums in amount of MI of Rs. 1,65,545, i.e., to reduce only 90 per cent of MI net of these amounts (or of Rs. 1,03,265), and not of Rs. 1,65,545 as done by him. 7. In result, appeal is dismissed. *** Assitant Commissioner of Income-tax v. Atlas Dye Chem Industrie