https://www.taxtmi.com/caselaws?id=26755 Section 80-0 approval depended on the real substance of the arrangement, not the nominal contracting party. Technical services were rendered wholly in Kuwait for the Government of Kuwait, consideration was received in foreign exchange, and the contract was commercially genuine. On that basis, the Indian company's role as immediate counterparty did not defeat eligibility. The statutory object of encouraging export of Indian technical know-how and foreign exchange earnings required a practical, substance-based reading, so approval could not be refused merely because the formal contract was with an Indian intermediary. en-us Mon, 10 Jun 1985 00:00:00 +0530 Mon, 08 Feb 2010 12:50:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=26755 Section 80-0 approval depended on the real substance of the arrangement, not the nominal contracting party. Technical services were rendered wholly in Kuwait for the Government of Kuwait, consideration was received in foreign exchange, and the contract was commercially genuine. On that basis, the Indian company's role as immediate counterparty did not defeat eligibility. The statutory object of encouraging export of Indian technical know-how and foreign exchange earnings required a practical, substance-based reading, so approval could not be refused merely because the formal contract was with an Indian intermediary. Case-Laws Income Tax Mon, 10 Jun 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=26755