https://www.taxtmi.com/caselaws?id=25981 Section 80-O approval cannot be refused merely because the assessee lacks direct contractual privity with the foreign enterprise. Where an approved agreement identifies the personnel and technical services, and the foreign enterprise accepts the assessee's participation, the statutory requirement is met; unlike section 80MM, section 80-O does not expressly require an agreement directly with the other contracting party. Convertible foreign exchange received abroad through an Indian intermediary also satisfies the receipt condition where the intermediary acts as the assessee's collection agent, retains only its agreed share, and brings the balance into India on the assessee's behalf. The agreement consequently qualifies for section 80-O relief. en-us Mon, 14 Oct 1985 00:00:00 +0530 Tue, 02 Feb 2010 11:07:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25981 Section 80-O approval cannot be refused merely because the assessee lacks direct contractual privity with the foreign enterprise. Where an approved agreement identifies the personnel and technical services, and the foreign enterprise accepts the assessee's participation, the statutory requirement is met; unlike section 80MM, section 80-O does not expressly require an agreement directly with the other contracting party. Convertible foreign exchange received abroad through an Indian intermediary also satisfies the receipt condition where the intermediary acts as the assessee's collection agent, retains only its agreed share, and brings the balance into India on the assessee's behalf. The agreement consequently qualifies for section 80-O relief. Case-Laws Income Tax Mon, 14 Oct 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25981