Deduction u/s 80-O was allowable on Overseas Advisory Services rendered from India

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 ba

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