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2011 (4) TMI 435 - HC - Income TaxDeduction u/s 80HHD - shopping commission - foreign tourists - It is clear from the bare reading of the provision that the income which is "derived from the services rendered to foreign tourists" would qualify for deduction under section 80HHD - assessee was receiving the commission from shopkeepers and not in foreign exchange from the tourists directly - it is essentially for the assessee to show that the profits earned by him are derived from services provided to foreign tourist - this provision is made to encourage those engaged in the hotel business or tour operators who are earning in convertible foreign exchange by rendering services to foreign tourists - The pre-condition stipulated in 80HHD of the Act is, therefore, not satisfied - Deduction u/s 80HHD not allowed.
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