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    <title>2002 (3) TMI 217 - ITAT DELHI-A</title>
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    <description>Amendments to section 80HHD introducing eligibility for hotels, tour operators and travel agents receiving Indian currency on behalf of foreign tourists were treated as prospective, not retrospective, because they enlarged the class of recipients and imposed a new certificate condition; deduction was therefore unavailable for assessment year 1989-90. Receipts from authorised restricted money-changing activity were also held ineligible, as that activity was regarded as a statutory facility rather than profit derived from services to foreign tourists, with no profit element shown and the income not forming part of gross total income. The assessee&#039;s claim for deduction under section 80HHD failed on both grounds, and the disallowance was sustained.</description>
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    <pubDate>Thu, 28 Mar 2002 00:00:00 +0530</pubDate>
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      <title>2002 (3) TMI 217 - ITAT DELHI-A</title>
      <link>https://www.taxtmi.com/caselaws?id=62997</link>
      <description>Amendments to section 80HHD introducing eligibility for hotels, tour operators and travel agents receiving Indian currency on behalf of foreign tourists were treated as prospective, not retrospective, because they enlarged the class of recipients and imposed a new certificate condition; deduction was therefore unavailable for assessment year 1989-90. Receipts from authorised restricted money-changing activity were also held ineligible, as that activity was regarded as a statutory facility rather than profit derived from services to foreign tourists, with no profit element shown and the income not forming part of gross total income. The assessee&#039;s claim for deduction under section 80HHD failed on both grounds, and the disallowance was sustained.</description>
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      <pubDate>Thu, 28 Mar 2002 00:00:00 +0530</pubDate>
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