1998 (3) TMI 6 - SUPREME COURT

Agreement by assessee with a foreign enterprise - non-approval of agreement by CBDT u/s 80-O - agreement makes it clear that that it provided for rendering of not only technical services for operating the hotel of the foreign enterprise but also providing for professional and other services in connection with operating of the hotel - hence in view of amendment of section 80-O by Finance Act 1991, CBDT was not justified in not granting approval of agreement