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Deduction u/s 80-O was allowable on Overseas Advisory Services rendered from India
Case Law Details
- Case Name
- DSP Merrill Lynch Limited Vs ACIT (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 1994-95
- Courts
- All ITAT, ITAT Mumbai
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DSP Merrill Lynch Limited Vs ACIT (ITAT Mumbai)
Conclusion: Professional and technical advisory services rendered from India to foreign clients in connection with overseas securities offerings qualify for deduction under Section 80-O as there was coordinate Bench’s decision in the assessee’s own case for AY 1995-96 and lower authorities disallowed portion merely because FIRC did not specify service details which was based on “suspicion, conjectures or surmises” rather than evidence.
Held: Assessee was a company engaged in merchant banking, investment advisory and broki...
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