(1.) Leave granted in the Special Leave Petitions.
(2.) The question for consideration in all these appeals is whether the benefit of an entitlement to make duty free imports of raw materials obtained by the assessee through advance licences and duty entitlement pass book issued against export obligations is income in the year in which the exports are made or in the year in which the duty free imports are made.
(3.) In our opinion, the income does not accrue in the year of export but in the year in which the imports are made.