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33. Above sub section allows an assessee to claim the benefit of the said section for export proceeds which are brought into India within a period of six months or within a further period as allowed by competent authority. Explanation (1) clearly states that competent authority is RBI. AP (DIR) series Circular No.91, dt.01.04.2003 of RBI states as under :

"A. Realisation of export proceeds In terms of para 11© of AP (DIR Series) Circular No.28, dated March 30,2001, units situated in Special Economic Zones have been permitted to realize and repatriate to India the full value of goods or software within a period of twelve months from the date of export. It has now been decided to remove the stipulation of twelve months or extended period thereof for realization of export proceeds. Accordingly, there shall be no prescription of any time limit for realization of exports made by units in SEZs. However, the units in SEZs will continue to follow the FR/PP.SOFTEX export procedure outlined in Part B of Annexure to A. P. (DIR Series) Circular No.12 dated September 9, 2000 as amended from time to time."