https://www.taxtmi.com/caselaws?id=5652 The dominant issue was whether an agreement for rendering hotel-management related expertise to a foreign enterprise qualified for CBDT approval under s. 80-O, and whether refusal of approval was legally sustainable. Interpreting "technical services" purposively, the SC held-consistent with prior precedent-that the 1991 amendment was clarificatory and "technical services" always encompassed professional services; the agreement involved making available industrial, commercial or scientific knowledge, experience or skill for use outside India to earn foreign exchange. The SC further held that CBDT's non-speaking refusal rested on irrelevant considerations and was amenable to judicial review; consequently, the HC's decision directing relief was affirmed and the revenue's appeal was dismissed. en-us Mon, 30 Mar 1998 00:00:00 +0530 Tue, 06 Jan 2026 15:46:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5652 The dominant issue was whether an agreement for rendering hotel-management related expertise to a foreign enterprise qualified for CBDT approval under s. 80-O, and whether refusal of approval was legally sustainable. Interpreting "technical services" purposively, the SC held-consistent with prior precedent-that the 1991 amendment was clarificatory and "technical services" always encompassed professional services; the agreement involved making available industrial, commercial or scientific knowledge, experience or skill for use outside India to earn foreign exchange. The SC further held that CBDT's non-speaking refusal rested on irrelevant considerations and was amenable to judicial review; consequently, the HC's decision directing relief was affirmed and the revenue's appeal was dismissed. Case-Laws Income Tax Mon, 30 Mar 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5652