TMI Blog2004 (11) TMI 30X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee through both these divisions was carrying on the activities which fell within the provisions of section 80-O - Explanation (iii) to section 80-O provide that "Services rendered or agreed to be rendered outside India shall include services rendered from India but shall not include services rendered in India." – further, Circular No. 700 dated March 23, 1995 states that “as long as the tec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he said decision dated June 5, 2002, the Revenue preferred appeal under section 260A of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), and the court framed the question as under: "Whether, the assessee has fulfilled the conditions as prescribed under section 80-O of the Income-tax Act, 1961, to be eligible for deduction?" This question was framed as the decisions rendered by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... idering the facts has pointed out that the assessee through both these divisions was carrying on the activities which fell within the provisions of section 80-O of the Act. In the dyeing services division, the information supplied out of India was in respect of research, local suppliers for various products/goods, information on the availability of products, information on market condition, etc. T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat this decision is rendered much before the insertion of Explanation (iii) to section 80-O of the Act, which reads as under: "Services rendered or agreed to be rendered outside India shall include services rendered from India but shall not include services rendered in India." Again our attention was drawn to the circular issued by the Central Board of Direct Taxes itself being Circular No. 7 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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