JUDGMENT

Dinesh Maheshwari, J.

PRELIMINARY WITH BRIEF OUTLINE

Leave granted.

2. The short point calling for determination in these appeals against the common judgment dated 09.06.2016 passed by the High Court of Kerala at Ernakulam in a batch of appeals is as to whether the income received by the appellants in foreign exchange, for the services provided by them to foreign enterprises, qualifies for deduction under Section 80-O of the Income Tax Act, 1961 [Hereinafter also referred to as ‘the Act of 1961’ or ‘the Act’], as applicable during the respective assessment years from 1993-94 to 1997-98.

3. Put in a nutshell, the question involved in these appeals has arisen in the backdrop of facts that the appellants herein, who had been engaged in providing services to certain foreign buyers of frozen seafood and/or marine products and had received service charges from such foreign buyers/enterprises in foreign exchange, claimed deduction under Section 80-O of the Act of 1961, as applicable for the relevant assessment year/s. In both these cases, the respective Assessing Officer/s [‘AO’ for short] denied such claim for deduction essentially with the finding that the services rendered by res