JUDGMENT

VERMA, J. :- Leave granted in all the special leave petitions.

Civil Appeal No. 7153 of 1994 (arising out of SLP (C) No. 20837 of 1993).

2. The Import and Export Policy for the period 1-4-1993 to 31-3-1994 was declared by the Central Government by issue of an order in exercise of the powers conferred by Section 3 of the Import and Export (Control) Act, 1947 giving general permission for import into India of raw materials, components and consumables by actual users (industrial) subject to certain conditions which included the follwing :-

"22. Items convered under Part-III of the Schedule to this licence can be imported under OGL by Actual Users (Industrial) and others, for stock and sale;"

"26. Such goods are shipped on through consignment to India on or before 31st March, 1984 or, in the case of Actual Users (Industrial) on or about 30th June; 1984 against confirmed orders for which irrevocable letters of credit are opened and established on or about 29-2-1984 with no grace period whatsoever."

3. Split stearin fatty acids were not a canalised item under that Policy. The appellants entered into a contract with a foreign supplier for import of fatty acids on 1-8-1983 and on 3-10-