JUDGMENT Order Delay condoned. Learned counsel for appellant submits that in view of decision of this court in Topman Exports v. CIT [2012] 342 ITR 49 (SC) this civil appeal deserves to be allowed and matter needs to be sent back to Assessing Officer. On other hand, submission of learned counsel for appellant is contested by Mr. R. P. Bhatt, learned senior counsel for Revenue. Having regard to controversy involved in matter, we are satisfied that this matter is squarely covered by decision of this court in Topman Exports. In Topman Exports this court concluded as follows (page 67): "The aforesaid discussion would show that where assessee has export turnover exceeding Rs. 10 crores and has made profits on transfer of DEPB under clause (d) of section 28, he would not get benefit of addition to export profits under third or fourth proviso to sub-section (3) of section 80HHC, but he would get benefit of exclusion of smaller figure from'profits of business' under Explanation (baa) to section 80HHC of Act and there is nothing in Explanation (baa) to section 80HHC to show that this benefit of exclusion of smaller figure from'profits of business' will not be available to assessee having export turnover exceeding Rs. 10 crores. In other words, where export turnover of assessee exceeds Rs. 10 crores, he does not get benefit of addition of ninety per cent. of export incentive under clause (iiid) of section 28 to his export profits, but he gets higher figure of profits of business, which ultimately results in computation of bigger export profit. High Court, therefore, was not right in coming to conclusion that as assessee did not have export turnover exceeding Rs. 10 crores and as assessee did not fulfil conditions set out in third proviso to section 80HHC(iii), assessee was not entitled to deduction under section 80HHC on amount received on transfer of DEPB and with view to get over this difficulty assessee was contending that profits on transfer of DEPB under section 28(iiid) would not include face value of DEPB. It is well-settled principle of statutory interpretation of taxing statute that subject will be liable to tax and will be entitled to exemption from tax according to strict language of taxing statute and if as per words used in Explanation (baa) to section 80HHC read with words used in clauses (iiid) and (iiie) of section 28, assessee was entitled to deduction under section 80HHC on export profits, benefit of such deduction cannot be denied to assessee. impugned judgment and orders of Bombay High Court are accordingly set aside. appeals are allowed to extent indicated in this judgment. Assessing Officer is directed to compute deduction under section 80HHC in case of appellants in accordance with this judgment..." For same reasons, impugned judgment and order of Gujarat High Court is set aside and Assessing Officer is directed to compute deduction under section 80HHC of Income-tax Act, 1961, in light of observations made by this court in Topman Exports as noted above. Civil appeal is allowed as above with no order as to costs. *** Global Agro Products P. Ltd. v. Income-tax Officer