JUDGMENT

Paripoornan, J.-The petitioner in Writ Petition No. 3086 of 1987 in the High Court of Delhi, has filed this appeal against the judgment of the High Court dated 29.10.1987. The short matter that arises for consideration in this appeal is the interpretation to be placed on Section 80-O of the Income-tax Act, 1961. Appellant is a private Company. It is engaged in the brokerage business as reinsurance-brokers. It receives a commission @ 3 to 6 per cent, relating to maritime and other insurance. The Respondent is the Central Board of Direct Taxes, Government of India, New Delhi. In respect of insurance risk covered by Indian or foreign insurance companies, appellant arranges for the reinsurance of a portion of risk with various reinsurance companies either directly or through foreign brokers. In return for the above services, the appellant company receives a percentage of the premium received by the foreign companies as its share of brokerage. For a period of 19 months from 1.3.1980, Oil and Natural Gas Commission insured all their offshore oil and gas exploration and production operation with the United India Insurance Company, Madras. In respect of this insurance risk, the app