In Brief
The Supreme Court held that an assessee is entitled to claim a tax deduction under Section 43B of the Income Tax Act for excise duty paid in advance and deposited in a Personal Ledger Account (PLA). Although the deposit is adjusted against subsequent clearances, it constitutes actual payment because the assessee loses control over the deposited amount, which stands credited to the Revenue. The court affirmed decisions by the Delhi and Punjab & Haryana High Courts, noting the assessee's consistent practice accepted by the Revenue for years and the legislative intent to prevent accrual-based deductions without actual payment to the State.
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