Dama Seshadri Naidu, J.

Introduction:

1. In this batch of Income Tax Appeals, an identical question of law arises: the scope and ambit of Section 80-O of the Income Tax Act (‘the Act’), as the provision was existing during the assessment year 1993-94.

2. Since all the other appeals have been decided based on the order of the Tribunal in the matter of the assessee who is the appellant in ITA No.132 of 2002, we shall refer to the facts of the said case for discussion and elucidation. Further, given a common question of law under identical fact situation arises, we also deem it appropriate to render a common judgment in all the appeals.

Facts:

3. The facts in brief, in the words of the appellant, are that ITA. No. 131/2002 & connected cases the appellant firm is an assessee engaged, mainly, in the business of providing commercial services to certain foreign enterprises. For the assessment year 1993-1994, the assessing officer disallowed the assessee's claim for deduction under Section 80-O of the Act on the premise that the assessee has not fulfilled the conditions laid down in the said provision. Aggrieved by the denial of deductions, the assessee filed an appeal. We may, howeve