COMMISSIONER OF INCOME TAX vs STERLING FOODS

The Supreme Court held that the Karnataka High Court erred in allowing the assessee to include the sale proceeds from import entitlements in its income for computing relief under Section 80HH of the Income-tax Act, 1961. The Court emphasized that the earlier decision against the assessee in 150 ITR 293 should have been followed, as the amendments to Section 28 of the Act were not relevant to the issue at hand. Consequently, the appeal by the Revenue was allowed, and the High Court's decision was set aside.