Supreme Court of India

Ramnath & Co. v. The Commissioner of Income Tax

Neutral citation
Bench A. M. Khanwilkar and Dinesh Maheshwari JJ.
Decided 5 June 2020

INSC stands for INDIAN SUPREME COURT. A neutral citation scheme assigned by the Court itself, so a judgment can be cited without depending on a commercial law reporter. INSC is the neutral citation scheme assigned by the Supreme Court, so a judgment can be cited without depending on a commercial law reporter.

What the Court ordered

We hold that the proceedings of the Central Board of Direct Taxes dated March 11, 1986, declining to approve the agreements of the appellant with Sedgwick Offshore Resources Ltd., London, for the purposes of section 80-O of the Income-tax Act, are improper and illegal.

Judgment, page 63

From the headnote

Income Tax Act, 1961 – s. 80-O – The appellants-assessees were engaged in providing services to certain foreign buyers of frozen seafood and/ or marine products – Appellants claimed that income received by them for services provided to foreign enterprises qualifies for deduction u/s. 80-O of the Income Tax Act, as applicable during the respective assessment years from 1993-94 to 1997-98 – Appellants contended that they provided technical guidance or advice or information to the foreign enterprises – Held: All the clauses of the agreements read together make it absolutely clear that the…

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