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 held that the right to receive such benefits becomes vested only upon making the imports, thus establishing a clear principle regarding the timing of income recognition in tax matters. The appeals were decided in favor of the assessee, affirming the lower appellate authority's decision.