( 1 ) THE petitioner is a chartered accountant engaged in providing professional services to various Indian and foreign clients. Services to foreign clients are provided in terms of the agreement entered into from time to time. The petitioner entered into agreements with Mannesmann A. G. , Germany on 15. 2. 1990 and with Fried Krupp GMBH, Germany on 8. 4. 1991. These agreements have been renewed from time to time. The relevant clause in the agreements entered into with the two companies is identical in terms. It is as under :-

CONSULTANT ( i. e. petitioner) shall provide to Mannesmann/krupp from time to time advice, information on finance, industrial, business and economic matters relating to India as would be useful to Mannesmann/krupp and its affiliated company in relation to its business investment in India.

( 2 ) EACH of the two companies agreed to pay a fee of DM 16000 per year in consideration of the services provided by the petitioner.

( 3 ) THE petitioner was granted approval under Section 80 RRA for the financial years 1991-92 to 1994-95. The petitioner sought for a similar approval by way of extension/renewal being granted for the financial year 1995-96. T