1991 (12) TMI 87

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....nd raised is that the CIT(A) erred in directing the ITO to allow relief under s. 80RR on the full amount of Rs. 3,91,570 and holding that no portion of the expenditure incurred in India could be relatable to foreign receipts. 2. The Departmental Representative referred to the provisions of s. 80AB of the Act and argued that some portion of the expenses had to be allocated against s. 80RR receip....

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....not a single item of expenditure was incurred abroad in foreign exchange. These receipts were obtained from the concerts staged by her for which all the expenses of travelling as well as earnings from the concerts were made by the sponsors and no portion of the expenses for such concerts was required to be incurred by her. 4. Next, the learned counsel for the assessee pointed out that the natur....

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....,262. 6. As regards expenses, all these expenses were incurred in India and no portion of the expenses were to be incurred for concerts organised abroad which fetched the aforementioned income. In a letter dt. 12th Feb., 1989, the assessee had clearly stated that air ticket was sent by the sponsors and all expenses for stay in foreign countries were also made by the sponsors. In the meanwhile, ....