Supreme Court of India
Ramnath & Co. v. The Commissioner of Income Tax
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
In view of the foregoing discussion, we are of the considered opinion that in the present facts and circumstances of the case, the services of managing agent, i.e., the appellant, rendered to a foreign company, are not technical services within the meaning of section 80-O of the Income-tax Act.
Judgment, page 69
From the headnote
Income Tax Act, 1961 – s. 80-O – The appellants-asses sees were engaged in providing services to certain forei gn buyers of frozen seafood and/ or marine products – Appellants c laimed that income received by them for services provided to forei gn enterprises qualifies for deduction u/s. 80-O of the Income Tax Act, as a pplicable during the respective assessment years from 1993-94 to 1997-98 – Appellants contended that they provided technical g uidance or advice or information to the foreign enterprises – Held: All the clauses of the agreements read together make it abs olutely clear that the
Authorities it was built on
- 2018 Commissioner of Customs (import), Mumbai v. M/s. Dilip Kumar and Company & Ors.
- 2006 M/s. Crawford Bayley and Co. and Ors. v. Union of India and Ors.
- 2017 Abhiram Singh v. C.D. Commachen (dead) by Lrs. & Ors.
- 2016 C.I.T. & Anr v. Mis Yokogawa India Ltd
- 1998 Central Board of Direct Taxes and Ors. v. Oberoi Hotels (india) Pvt. Ltd.
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