Section 80-O of the Income-tax Act, 1961--Guidelines for approval of agreements--Further clarifications

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.... the above subject laying down the guidelines for the grant of approval under section 80-O. The Board has had occasion to re-examine the aforesaid guidelines and it has been decided to modify the guidelines to the extent indicated below:- (i) Para. 3(iii) of the Circular dated 23-12-1975 provided that the agreement should have been genuinely entered into on and after the date when the tax concess....

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....the Board may not approve such an agreement for the purposes of section 80-O of the Act if it was not possible to properly ascertain and determine the amount of the consideration relatable to the provision of the know-how or technical services, etc., qualifying for section 80-O. Thus, the benefit of section 80-O could be denied to the entire amount of royalty, commission, fees, etc., receivable un....