Foreign Contracts and Earnings Alone Don't Qualify for Section 80-O Deductions; Circular No. 700 Irrelevant.

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....Deduction u/s 80-O - royalties, etc. - Merely for having a contract with a foreign enterprise and mere earning foreign exchange does not ipso facto lead to the application of Section 80-O of the Act. - Circular No.700 is neither of any application to this case nor of any assistance to the appellant....