https://www.taxtmi.com/caselaws?id=395783 The SC upheld the HC's decision denying Section 80-O deduction to an assessee claiming foreign exchange earnings for services to foreign enterprises. The Court held that the assessee was merely a marine product procuring agent, not providing professional services from India. Despite contractual references to "expert information" and "technical guidance," the Court found these were incidental to the main agency function. Payment was based solely on goods invoiced, with no separate compensation for advisory services. The Court emphasized strict interpretation of exemption provisions, placing burden on assessee to prove eligibility. The services were rendered in India rather than from India, disqualifying the deduction claim. en-us Fri, 05 Jun 2020 00:00:00 +0530 Wed, 16 Jul 2025 11:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=395783 The SC upheld the HC's decision denying Section 80-O deduction to an assessee claiming foreign exchange earnings for services to foreign enterprises. The Court held that the assessee was merely a marine product procuring agent, not providing professional services from India. Despite contractual references to "expert information" and "technical guidance," the Court found these were incidental to the main agency function. Payment was based solely on goods invoiced, with no separate compensation for advisory services. The Court emphasized strict interpretation of exemption provisions, placing burden on assessee to prove eligibility. The services were rendered in India rather than from India, disqualifying the deduction claim. Case-Laws Income Tax Fri, 05 Jun 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=395783