Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2005 (11) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2005 (11) TMI 55 - DELHI HIGH COURTDeduction under section 80-O - foreign receipt - Tribunal upheld the order passed by the Commissioner of Income-tax (Appeals) and affirmed the finding that a sum of Rs. 92,91,442 out of a total foreign receipt of Rs. 2,13,35,647 did not qualify for deduction under section 80-O - while the ultimate beneficiary of the service rendered by the petitioner is located outside the country, the service for which the payments have been received by the appellant was rendered in relation to litigation pending in Indian courts. - The amounts received by the applicant, therefore, represented the remuneration of the work which the appellant-company had done for a foreign client in India. - The professional services could not, therefore, be said to have been rendered from or outside India so as to qualify for a deduction under section 80-O - no error in the orders passed by the Tribunal
|