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2014 (12) TMI 845 - ANDHRA PRADESH HIGH COURTDeduction u/s 80-O - submission of survey report to foreign agencies - Place for rendering services - Whether the services are said to have been rendered within India or outside India – Held that:- Explanation (iii) to section 80-O places an important role - It maintains a distinction between the service rendered from India on the one hand, and the service rendered in India on the other - Even if the services are rendered from India, the activity comes within the purview of Section 80-O of the Act - The distinction is that it must be from and not within - The first part of it i.e. service rendered from India connotes that the agency that is rendering service is within India, but the beneficiary thereof is from outside - The second part, namely service in India, takes in its fold, a situation where the agency that is rendering of service and the one who avails it are in India - It is only the former that qualifies - the words outside India become relevant - the mere fact that the submission of report was within India, does not take away the matter from the purview of Section 80-O – thus, the order of the Tribunal is upheld – Decided against revenue.
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