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    <title>2014 (4) TMI 79 - KARNATAKA HIGH COURT</title>
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    <description>The High Court upheld the reopening of the assessment under Section 147 of the Income Tax Act and ruled that the appellant was not entitled to the deduction under Section 80-O. The court found that the legal services provided by the appellant were conducted in India, despite fees being received in foreign exchange, thus not qualifying for the deduction. The court referenced relevant provisions and a CBDT circular, ultimately dismissing the appeal and affirming the decisions of the lower authorities.</description>
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      <description>The High Court upheld the reopening of the assessment under Section 147 of the Income Tax Act and ruled that the appellant was not entitled to the deduction under Section 80-O. The court found that the legal services provided by the appellant were conducted in India, despite fees being received in foreign exchange, thus not qualifying for the deduction. The court referenced relevant provisions and a CBDT circular, ultimately dismissing the appeal and affirming the decisions of the lower authorities.</description>
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