Chhotalal Samji vs Income Tax Officer

The Supreme Court addressed the interpretation of Section 28 of the Income-tax Act, 1961, particularly clauses (iiia) and (iiic), which were amended by the Finance Act, 1990, to include cash compensatory support, duty drawback, and profits from import entitlement licenses as taxable under 'Profits and Gains of Business or Profession'. The Court held that the High Court must reconsider the case regarding the inclusion of profits from the sale of DEPB licenses and duty drawback in business profits for computing deductions under Section 80HHC, as these issues were not previously decided. The appeal was allowed, restoring the matter for de novo consideration by the High Court.