Saluja J.M. - the assessee is in appeal against the order of CIT(A)-XVII, New Delhi dated 6-6-1994 mainly on the ground of disallowance of the Claim for deduction of Rs. 14,74.272 under section 80-O of the Income-tax Act.

2. The assessee filed the return of income on 30-10-1992 declaring nil income. the case was processed under section 143(1)(a) on 19-2-1993 and it was selected for scrutiny to vouch-safe the correctness of claim of deduction under section 80-O to the extent of Rs. 14,74,262. A notice was issued under section 143(2) and the assessee filed information/details and documents like copies of agreements etc. The Assessing Officer observed that the assessee was carrying on brokerage activities under the name and style of M/s. Interocean Company, 75 Link Road, New Delhi and that the assessee was a ship broker of the foreign ship-owners/ship charteres and received a specified commission @ 1.25% out of the hire charges remitted by the Indian clients to foreign ship-owners/charters in accordance with the agreements. He also observed that the agreements were being signed by the assessee for each transaction of hiring ships on behalf of the foreign ship-owners/charterers as