account of restriction of deduction under s. 80RR . The learned counsel for the assessee relied upon the following decisions in support of the contention that ... 16th November, 1995.
It was further contended that deduction under s. 80RR has been allowed by the Department in full for asst
Officer's rejection of the Appellant's claim under Section 80RR on the footing that the Appellant's case does not fall ... within the ken of Section 80RR.
(ii) On the facts and circumstances of the case and in law, the learned Commissioner of Income Tax (Appeals
that the appellant is not an actor within the meaning of Section 80RR of the IT Act and hence not entitled to deduction claimed under ... Section 80RR of Rs. 6,87,198 by the appellant and learned CIT(A) erred in confirming the same.
2. The learned ITO has erred
receipt of Rs. 2,39,477 claimed by the assessee under section 80RR of the Income Tax Act, 1961, pertaining to the assessment year ... assessment year under appeal, the assessee claimed deduction under section 80RR amounting to Rs. 1,79,608 on royalty income
issue, i.e., denial of deduction by the Revenue authorities under Section 80RR of the IT Act in respect of income ... exercise his profession in earning the aforesaid income, deduction under Section 80RR is not admissible. The learned CIT(A) approved the view taken
Shri Sunil Gavaskar
as all the conditions stipulated u/s 80RR are satisfied.
3. On the facts & circumstances of the case the
appellant prays ... very much eligible as per law to claim
deduction under section 80RR and inconsistent stand of the
Revenue is not only legally invalid but also
claim of
assessee amounting to Rs. 1,09,92,953/- u/s 80RR ignoring
the fact that the assessee had filed necessary certificates in
form ... duly
supported by FIRCS. The AO has denied the deduction u/s 80RR on
such receipts brought in India and has also disallowed payments
holding that the appellant is not eligible for deduction under Section 80RR of the IT Act, 1961 and the reasons assigned by him in this ... Form No. 10H for the purpose of claiming deduction under Section 80RR of the Act. Subsequently, during the course of assessment proceedings the assessee filed
grounds No. 2. Ground No.3 pertains to
deduction under section 80RR which was not allowed by the
A.O. and learned ... appeal is with
reference to claim of deduction under section 80RR amounting
to Rs.40,00,197/- being 75% of foreign receipts
legal expenses Rs.4,25,000/- and disallowance of deduction u/s.80RR
Rs.1,56,712/-, vide order dated 17.11.2006 passed ... Ground No.5 is against the disallowance of deduction u/s.80RR.
20. The brief facts of the above issue are that it was observed
