The respondent's appeal against the Assessing Officer's ruling was upheld by the Commissioner of Income Tax (Appeals), granting full deductions under Section 80HHC, a decision subsequently affirmed by both the ... Income Tax Appellate Tribunal and the High Court despite the Revenue's challenges, which then escalated to the Supreme Court through a Special Leave Petition arguing the ineligibility of the respondent, as a supporting manufacturer, for such deductions on par with direct exporters.