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Issues involved: Construing the applicability of s. 80-O of the Income-tax Act to agreements entered into by the petitioner, refusal of approval by the respondent, and eligibility for deduction under s. 80-O.
In Civil Writ No. 767 of 1975, the agreement between the petitioner and the British Broadcasting Corporation (BBC) was scrutinized. The court analyzed whether the services rendered by the petitioner, including audience research study in India, qualified for deduction u/s 80-O. The court interpreted the requirement that the information supplied must concern industrial, commercial, or scientific knowledge, and concluded that the statistical information compiled by the petitioner for the BBC constituted commercial or scientific knowledge. It was held that the petitioner was entitled to the benefit of s. 80-O, and the order refusing approval was quashed. In Civil Writ No. 768 of 1975, a similar agreement with BBC was considered. The court reiterated that the petitioner was eligible for the benefit of s. 80-O in this case as well. The order of the respondent refusing approval was set aside, and the petitioner was declared entitled to the deduction under s. 80-O. In Civil Writ No. 769/75, the agreement between the petitioner and Nippon Research Centre Ltd. of Japan was reviewed. The court found that the nature of this agreement was akin to the previous agreements with BBC, involving the collection of information for statistical analysis. Consequently, the petitioner was deemed eligible for the benefit of s. 80-O in this agreement too. The order of the Board refusing approval was quashed, and the petition was allowed with no order as to costs.
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