1992 (1) TMI 74

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....il 17, 1986. A direction for affidavits was given on that date. No affidavit has been filed even till now. The dispute is about the interpretation of section 80-0 of the Income-tax Act. The petitioners had made two applications to the Board both dated September 19, 1980, for approval of two agreements, one dated June 15, 1978, and the other dated July 16, 1979, with M/s. General Navigation and Com....

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....e technicians deputed by you, your assertions cannot be corroborated. Apparently, the two agreements are for the mere supply of technical personnel for service outside India. According to the guidelines contained in para 3(vi) of the Board's Circular No. 187 dated December 23, 1975, agreements for the mere supply of technical personnel for service outside India are outside the scope of section 80-....

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....outside India. Having regard to the object of section 80-0, the Board's objection does not appear to be lawful. If the petitioners agree to render technical services outside India to foreign enterprises and receive income in foreign exchange for such services, then the agreements of the petitioners are clearly within the scope of section 80-0. It is not understood as to why the Board is objecti....