1990 (8) TMI 136

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..... ted September 12, 1986, issued by the Ministry of Finance, Department of Revenue, Foreign Tax Division, Government of India, New Delhi. The petitioner had entered into two agreements dated November 3, 1980, and September 1, 1981, with the Ontario Paper Company Limited of Canada for rendering services to that company in and outside India on remuneration as per the agreements. The petitioner's app .....

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..... e application in the following terms: "I am directed to refer to your application dated March 4, 1986, and subsequent submissions dated June 5, 1986, on the above subject and to say that you have not rendered any service outside India as a technician within the meaning of section 80RRA of the Income-tax Act, 1961. It is, therefore, regretted that the terms and conditions of your service with Ont .....

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..... ter dated March 27/April 27, 1982, further shows that the applications have not been considered properly. The impugned letter dated September 12, 1986, is, therefore, set aside with a direction to the Government to consider the petitioner's application for approval of the agreements under section 80RRA afresh according to law and to pass a speaking order. Rule is accordingly made absolute in ter .....

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