2014 (12) TMI 302

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..... t exercising the option of importing the goods by the department – Following the decision in The same issue has come up for consideration before the Full Bench of the Supreme Court in the case of Commissioner of Income-tax v. Excel Industries Ltd. [2013 (10) TMI 324 - SUPREME COURT] – income does not accrue in the year of export but in the year in which the imports are made – Decided in favour of .....

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..... - has accrued as taxable income for the assessment year under consideration ? 3. The facts of the present case are that the return of income declaring total loss of ₹ 2,15,10,570/- was filed on 30.11.1996 along with the Audited Report in Form No. 3CA and 3CD as required u/s. 44AB of the I.T. Act, 1961. The return was processed under sec. 143(1)(a) of the Act and a statutory notice under .....

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..... ment order, the assessee has preferred an appeal before the CIT(A) which came to be partly allowed, against which, the assessee preferred an appeal before the Appellate Tribunal, which was dismissed, against which, the present Tax Appeal is preferred by the appellant-assessee. 4. Heard the learned advocates appearing for the respective parties and considered the submissions. The learned advocat .....

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