https://www.taxtmi.com/caselaws?id=5263 Section 80-0 requires direct receipt by an Indian company from a foreign State or a foreign enterprise under an approved agreement for technical know-how or services rendered outside India. The Court held that a "foreign enterprise" means an enterprise situated and constituted under foreign law; a branch, unit or establishment of an Indian company abroad does not become foreign merely by location. Liberal construction of the provision could not override its plain wording, and indirect satisfaction of the statutory object was insufficient. On that reading, payments received from an Indian company did not meet the statutory condition, so approval was rightly refused. en-us Tue, 13 Dec 1988 00:00:00 +0530 Tue, 28 Oct 2025 16:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5263 Section 80-0 requires direct receipt by an Indian company from a foreign State or a foreign enterprise under an approved agreement for technical know-how or services rendered outside India. The Court held that a "foreign enterprise" means an enterprise situated and constituted under foreign law; a branch, unit or establishment of an Indian company abroad does not become foreign merely by location. Liberal construction of the provision could not override its plain wording, and indirect satisfaction of the statutory object was insufficient. On that reading, payments received from an Indian company did not meet the statutory condition, so approval was rightly refused. Case-Laws Income Tax Tue, 13 Dec 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5263