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TMI Blog1981 (2) TMI 55X X X X Extracts X X X X X X X X Extracts X X X X ..... after " the assessee "). During the relevant previous year ending September 30, 1978 (assessment year 1979-80), the assessee entered, in the course of its business, into as many as nineteen agreements, mostly in the form of letters, with different parties of different places such as Tehran-Iran, Saudi Arabia, Bahrain and Dubai (UAE). In pursuance thereof, the assessee submitted to the CBDT, applic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... approval applications state that the assessee is not providing technical know-how but is claiming exemption under " information " which is imparted by means of " conveying the names " of suitable candidates by trunk call, telex or post. This process of information can, by no stretch, be said to partake of the nature of " ...industrial, commercial or scientific knowledge, experience or skill" with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , at times, by a representative of the foreign employer coming to India for that purpose. In several letters-cum-agreements the foreign employers have asked and/or authorised the assessee to itself select and recruit candidates in India and in some cases the assessee is asked to keep candidates ready for interview in India by a representative of the foreign employer. The entire service rendered by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ircumstances, to nevertheless accord approval as claimed would result in permitting evasion under the cover of deductions. Section 80-O of the Act provides for concessional tax treatment. Tax incentive contemplated thereunder is basically for encouraging Indian companies to export their know-how and skill abroad. Mere supply of particulars or bio-data of various Indians willing to work abroad and ..... X X X X Extracts X X X X X X X X Extracts X X X X
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