C.I.T Central-Iii vs M/S Excel Industries Ltd

The Supreme Court ruled that the income from duty-free imports under advance licenses and duty entitlement pass books is recognized in the year the imports are made, not in the year exports are completed, as per Section 28(iv) of the Income Tax Act, 1961. The Court upheld the decisions of the lower authorities, affirming that the benefits do not accrue until the raw materials are imported and consumed. Consequently, the appeal by the Revenue was dismissed, maintaining the tax treatment favored by the assessee.