Even promise to render services at a future date would entitle Assessee to deduction u/s 80O of the Income Tax Act, 1961

The AO as well as the CIT(A) were wrong in coming to a conclusion that the assessee is not entitled to deduction u/s 80-O on the ground that it has only deputed certain personnel for working in the foreign enterprises. Even a promise to render services at a future date would entitle the assessee for deduction u/s 80-O in view of the specific wordings in the section. When the assessee is not a dealer in foreign exchange and when the transaction is purely incidental to the assessee’s regular course of business the loss would be allowable. It has further been specifically held that foreign ...