https://www.taxtmi.com/caselaws?id=25121 For section 80-0 of the Income-tax Act, 1961, a "foreign enterprise" is construed as an enterprise of foreign nationality or foreign ownership, so an Indian company's branch or unit situated abroad does not qualify on that basis. The note also states that approval under section 80-0 does not depend on the agreement itself being entered into with a foreign State or a foreign enterprise; the statute requires the income to arise from the specified use of rights or technical services, but does not add a separate counterparty . On that construction, the objection to approval based on the contracting party was rejected, while the objection based on the Indian branch being a foreign enterprise failed. en-us Tue, 11 Aug 1987 00:00:00 +0530 Mon, 25 Jan 2010 15:26:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25121 For section 80-0 of the Income-tax Act, 1961, a "foreign enterprise" is construed as an enterprise of foreign nationality or foreign ownership, so an Indian company's branch or unit situated abroad does not qualify on that basis. The note also states that approval under section 80-0 does not depend on the agreement itself being entered into with a foreign State or a foreign enterprise; the statute requires the income to arise from the specified use of rights or technical services, but does not add a separate counterparty . On that construction, the objection to approval based on the contracting party was rejected, while the objection based on the Indian branch being a foreign enterprise failed. Case-Laws Income Tax Tue, 11 Aug 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25121