Objective of Sec. 80-O is mainly supply of technical know-how or technical services to developing countries

One thing is clear that the DR has not challenged the allowability of deduction u/s. 80-O, he has shown serious reservations on the basis of allowability, i.e. whether the deduction should be allowed on net amount or on gross amount.

The DR pointed out the decisions of Hon’ble Bombay High Court in the case of CIT Vs Asian Cable Corpn. Ltd. I.T. Reference No. 530 of 1987, reported in 129 Taxman 590. The DR has also referred to the decision of Hon’ble Karnataka High Court in the case of ACIT Vs Abcon Engg. & Systems (P)

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