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TMI Blog1986 (9) TMI 66X X X X Extracts X X X X X X X X Extracts X X X X ..... and derives its income from the manufacture of hosiery goods and their sale to U.S.S.R. through its purchase agency, M/s. Rozno Exports. It claimed weighted deduction under section 35B of the Income-tax Act, 1961 (hereinafter called " the Act "), on payment of commission of Rs. 3,10,749.99 to M/s. Singh and Co., New Delhi, and M/s. Handicraft Handloom Export Corporation, which was disallowed by t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nces, in Income-tax Case No. 20 of 1986, decided on May 12, 1986 [ CIT v. Bhagat Brothers [1987] 165 ITR 660 (P & H) ], we had issued a mandamus to the Tribunal for referring such a question. Now, after hearing Mr. G. C. Sharma, learned counsel for the assessee, we find that the implication of the opinion expressed by the Central Board of Direct Taxes in paragraph 7 of the Instruction No. 1487 dat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e rendering of services in connection with the provision of technical knowhow, to persons outside India ; and (b) The expenditure in relation to which weighted deduction has been claimed is incurred by the assessee wholly and exclusively for the purposes of the business referred to in (a) above. " These additional conditions contained in clauses (a) and (b) of paragraph 7 were introduced by the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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