ANIL DEV SINGH, J.

( 1 ). The petitioner is the wife of late Dr. Lal C. Verman, who had entered into an agreement with the General Electric Company (TEMPO), a company incorporated in New York, dated August 25, 1974, as modified subsequently by supplementary agreements dated November 4, 1977, and June 27, 1975. By that agreement Dr. Verman, who was the original petitioner, was retained by the company for the period commencing from August 25, 1974 to August 24, 1975. As per the terms of the agreement, Dr. Verman was required to perform his services at the rate of 138 dollars plus 17% per. day for each days work during the term of the agreement payable at the end of each month. He was to advice and act as a consultant to the company on problems relating to formulation of detailed plans and programmes for the development, staffing and equipment of the Korean Standard System. Petitioner s husband made an application to the Government of India for approval of the agreement under section 80-RRA of the Income Tax Act, 1961 (for short the Act ). This application was rejected by the Government of India by its letter dated February 28, 1976 for twin reasons, namely, (a) the relationship bet

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