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TMI Blog2005 (6) TMI 482X X X X Extracts X X X X X X X X Extracts X X X X ..... 2-1998 against the order of the ld. CIT(Appeals)-XIII, New Delhi dated 11-9-1998 in the case of the assessee in relation to assessment order under section 143(3) for assessment year 1992-93. 2. In this appeal, the revenue has disputed deduction of Rs. 60,077 allowed to the assessee by the ld. CIT(A) under the provisions of section 80-O of the Act. 3. Facts of the case leading to this appea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ave to waste their time and they could rely on the information/advice supplied by the assessee for the Indian clients. The ld. CIT(A) held that because of such services, deduction under section 80-O was available to the assessee on the amount of commission earned by the assessee in convertible foreign exchange. 4. During the hearing before me, the ld. DR argued that the assessee had not furnis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... were only incidental to the services rendered by the assessee in India. The ld. CIT(A) is, therefore, erred in allowing deduction under section 80-O to the assessee. 5. During the course of hearing before me, the ld. Authorized Representative of the assessee referred to a certificate dated 15-2-2005 from Foster and Freeman Limited of England. He requested that the same may be admitted as fres ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gument of the ld. DR that the services, if at all, were rendered as incidental to the main task of the assessee to procure orders in India for the foreign suppliers. At the same time, I am of the view that it would not be just and fair to ignore the contentions of the assessee altogether. Before the ld. CIT(A), the assessee has enumerated at length the nature of services rendered outside India. In ..... X X X X Extracts X X X X X X X X Extracts X X X X
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