Voltas International Ltd. v. Asstt. CIT

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The Tax Publishers2009 TaxPub(DT) 0661 (Mum-Trib) : (2010) 031 (II) ITCL 0417 : (2009) 126 TTJ 0702 : (2009) 031 DTR 0432 Voltas International Ltd. v. Asstt. CIT INCOME TAX ACT, 1961 Deductions under section 80-O - Allowability -Assessee rendered technical services out of India Assessee claimed deduction under section 80-O on account of technical services rendered out of India. AO disallowed the claim on ground that it had only deputed certain personnel for working in foreign enterprises. Held: As per Explanation 2 to section 9(1)(vii), rendering of any managerial, technical or consultancy services include provisions for services of technical and other personnel; since, assessee received technical service fee towards services rendered outside India, therefore, deduction was allowed under section 80-O to assessee. Income-tax Act, 1961, Section 80-O A.Y.: 1996-97 Decision: In favour of assessee. Voltas International Ltd. v. Asstt. CIT SUBSCRIBE FOR FULL CONTENT

The Tax Publishers2009 TaxPub(DT) 0661 (Mum-Trib) : (2010) 031 (II) ITCL 0417 : (2009) 126 TTJ 0702 : (2009) 031 DTR 0432

Voltas International Ltd. v. Asstt. CIT

INCOME TAX ACT, 1961

Deductions under section 80-O - Allowability -Assessee rendered technical services out of India

Assessee claimed deduction under section 80-O on account of technical services rendered out of India. AO disallowed the claim on ground that it had only deputed certain personnel for working in foreign enterprises. Held: As per Explanation 2 to section 9(1)(vii), rendering of any managerial, technical or consultancy services include provisions for services of technical and other personnel; since, assessee received technical service fee towards services rendered outside India, therefore, deduction was allowed under section 80-O to assessee.

Income-tax Act, 1961, Section 80-O

A.Y.: 1996-97
Decision: In favour of assessee.

Voltas International Ltd. v. Asstt. CIT