In Brief
The Supreme Court held that an assessee is entitled to claim a deduction under Section 43B of the Income Tax Act for excise duty paid in advance through a Personal Ledger Account (PLA). The Court found that advance deposits in the PLA constitute actual payment of duty within the meaning of the statute, despite subsequent adjustments against actual clearances. The Court emphasized that the assessee has no control over deposited amounts and emphasized consistency with the Revenue's long-standing acceptance of the assessee's accounting practice. The appeals were dismissed, affirming the decisions of the Delhi and Calcutta High Courts.
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