Section 80RRA deduction requires prior approval of foreign service terms; a mere application is not enough.

Deduction under section 80RRA for foreign service by a technician is available only when the terms and conditions of the overseas engagement are approved by the Central Government or the prescribed authority under section 80RRA(2)(ii). A pending application for approval does not satisfy that statutory requirement, and the absence of any recorded approval is fatal to the claim. Where no prescribed authority exists, approval by the Central Government remains necessary. On the facts stated, the mandatory precondition was not met, so the deduction was not allowable.

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Issues: Whether the assessee was entitled to deduction under section 80RRA of the Income-tax Act, 1961 without prior approval of the terms and conditions of services outside India by the Central Government or the prescribed authority under section 80RRA(2)(ii).

Analysis: Deduction under section 80RRA for a technician working outside India is available only if the terms and conditions of the foreign service are approved by the Central Government or the prescribed authority. The record contained no such approval. A mere application seeking approval could not substitute for the statutory requirement of approval, and where no prescribed authority existed, approval of the Central Government remained necessary.

Conclusion: The assessee did not satisfy the mandatory condition in section 80RRA(2)(ii), and the deduction was not allowable.

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