Acg Associated Capsules P.Ltd vs C.I.T Central-Iv Mumbai

The Supreme Court reversed the Bombay High Court's decision regarding the treatment of Duty Entitlement Pass Book (DEPB) sales under Section 28(iiid) of the Income Tax Act, 1961, clarifying that only the sale value less the face value of DEPB constitutes profit. Additionally, the Court addressed the computation of deductions under Section 80HHC, ruling that netting of interest and rent is permissible if a nexus is established, thereby remanding the matter for further assessment. The Court held that the High Court's directive on gross receipts exclusion was incorrect, aligning with its prior judgment in M/s Topman Exports.