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 busine

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