In this case, revenue has raised two grounds - one is about deleting addition of Rs. 6,19,058 as extra profit made by Assessing Officer and other is against directing Assessing Officer not to include in total turnover amount of sale proceeds not brought into India while computing deduction under section 80HHC. 2. Regarding first ground facts are that assessee is manufacturer and exporter of carpets. Assessing Officer noticed that manufacturing process involved weavers payment to whom is not verifiable. He rejected books of account and applied gross profit rate of 18.5 per cent as against 18.1 per cent declared by assessee. Ld. CIT(A) found that assessee has maintained proper details and, therefore, there was no justification in making addition. 3. We have heard ld. A.R. and ld. D.R. So far as applicability of provisions of section 145 was concerned, we are of view that it is applicable on facts of case as payments made to weavers/Karigars are not verifiable and there is no stock register as such of raw material and its correlation with carpets manufactured cannot be known. Further, as pointed out by Assessing Officer weaving charge paid to weavers/Karigars are not fully verifiable. It is not correlated to amount of work done by them. As such we accept proposition that profits cannot be deduced correctly from accounts maintained by assessee. However, we notice that in assessment year 2000-01 assessee has declared gross profit of 19.1 per cent on turnover of Rs. 18,38,06,662. In earlier year turnover declared was at Rs. 24,85,02,958 and G.P. declared was 24.48 per cent. Ld. A.R. submitted that export rates have gone down by 6.28 per cent whereas cost of production has remained constant. After considering arguments of ld. A.R. and ld. D.R., we restore issue of extra profit addition to file of Assessing Officer to work out ratio of sale rates to purchase rates for different material, weaving charges and compare them with last three years and work out as to whether there has been markable variation as compared to assessment year 1999-2000, where G.P. rate shown was 24.48 per cent. After analysing various rates, Assessing Officer will find out as to whether G.P. rate declared at 18.1 per cent is reasonable or any addition is called for. This ground of revenue is, therefore, allowed for statistical purposes. 4. next ground is of excluding export purchases not realised from total turnover. Ld. Assessing Officer was of view that export sale proceeds not realised could not be excluded from definition of total turnover because of Explanation (ba) in section 80HHC. Ld. CIT(A), however, was of view that after decision of Hon'ble Kerala High Court in CIT v. Abad Fisheries [2002] 258 ITR 641, sale proceeds not realised could not be included in total turnover as they do not form part of actual profit. 5. Before us, ld. D.R. relied on definition of total turnover in Explanation (ba) in section 80HHC whereas ld. A.R. for assessee submitted that only export turnover has been defined and not total turnover. He relied on decision of Kerala High Court as referred by ld. CIT(A) in her order. 6. We have considered rival submissions and perused material on record. only dispute is whether sum of Rs. 11,10,377 being export bill, which were not realised up to extended period, could be included in total turnover while computing deduction under section 80HHC. In formula for computing deduction under section 80HHC, items to be included are export turnover, total turnover and total profit. Export turnover is defined by Explanation (b) as under: '(b) 'export turnover' means sale proceeds, received in, or brought into, India by assessee in convertible foreign exchange in accordance with clause (a) of sub-section (2) of any goods or merchandise to which this section applies and which are exported out of India, but does not include freight or insurance attributable to transport of goods or merchandise beyond customs station as defined in Customs Act, 1962 (52 of 1962).' Whereas total turnover is defined by Explanation (ba) as under: '(ba) 'total turnover' shall not include freight or insurance attributable to transport of goods or merchandise beyond customs station as defined in Customs Act, 1962 (52 of 1962).' 7. Thus, as per these definitions export turnover would include only those sale proceeds which are received in India or brought into India. Thus, sale proceeds not realised by assessee will not form part of export turnover. However, total turnover cannot exclude sale proceeds not realised because it is what comprised of total business of assessee and what will not be included if clearly specified in Explanation (ba). They are only freight, insurance, attributable to transport of goods or merchandise beyond custom station as defined in Customs Act. As per proviso, after 1st April, 1991, items covered in section 28 as mentioned in proviso, will also be excluded. Thus, there are specific exclusion provided in Explanation (ba). Therefore, other items could not be excluded like sale proceeds not realised. Since sale proceeds not realised will not form part of export, then proportionate profit worked out as per formula will not include profit on such unrealised export. It may be mentioned here that total profit i.e., computed business profit will include profit as computed according to profit and loss account which include total turnover and which, in turn, includes sale proceeds not realised. Thus, in formula computed business profit includes profit on not realised sale proceeds. Therefore, total turnover will also include sale proceeds not realised. formula for computation of deduction under section 80HHC, as given by Assessing Officer, is as under: 80 per cent of computed business profit E.T.O./T.T.O + 90 per cent of export incentive E.T.O./T.T.O. From this, it is clear that profit of export proceeds not realised, if it forms part of computed business profit, then it is also going to form part of total turnover in denominator. This is in accordance with Explanation (ba). We, therefore, uphold view point of revenue and on this account order of ld. CIT(A) is reversed and that of Assessing Officer is restored. 8. So far as decision in Abad Fisheries' case (supra) is concerned, it is not different than view we have taken. Profit on unrealised sale proceeds is forming part of total business profit. Therefore, it will form part of total turnover also. If it has to be excluded from business profit, then it will have to be excluded from total turnover also. Thus, this ground of revenue is allowed. 9. As result, appeal of revenue is allowed in part. *** ASSISTANT COMMISSIONER OF INCOME TAX v. ISHAR INTERNATIONAL