Supreme Court of India

Continental Construction Ltd. v. Commissioner of Income-tax, Central-i

Neutral citation
Reported as [1992] 1 S.C.R. 57
Bench S. Ranganathan, V. Ramaswami and N. D. Ojha JJ.
Decided 15 January 1992

INSC stands for INDIAN SUPREME COURT. A neutral citation scheme assigned by the Court itself, so a judgment can be cited without depending on a commercial law reporter. INSC is the neutral citation scheme assigned by the Supreme Court, so a judgment can be cited without depending on a commercial law reporter.

What the Court ordered

We hold that the assessee was entitled to the relief under section 80-0 for assessment years earlier to 1983-84 and that the approval granted by the Board under that section was right and proper.

Judgment, page 60

From the headnote

Income-Tax Act, 1961 : Ss. 9(1)(vi), (vii), 119(1), 80-0, 80-HHB : Assessee-Engineering and Construction Company-Undertaking of foreign projects-Approval by Central Board of Direct Taxer-Payments in respect of consideration for supply of technical information for use outside India and rendering Technical Services to foreign Government Enterprise-­ Whether 'similar' to 'royalty', 'Commission' or 'fee' etc.-Deductions­ Scope of-Assessee-Whether entitled to relief under S. 80-0 for assessment years earlier to 1983-84-Whether eligible for deductions under s. 80-HHB for assessment years 1983-84

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