P.K.Mukharji, J. - (1.) The order passed by the Central Board of Direct Taxes refusing to accord " approval", under Section 80-O of the Income-tax Act, 1961, dated January 4, 1977, has been impugned in the present writ petition by the petitioner company, M/s. Simon Carves (India) Limited.
(2.) In communicating the said impugned order, the Under Secretary to the Central Board of Direct Taxes has referred to the petitioner's letter dated September 26, 1975, which was the application for grant of " approval" under Section 80-0 of the Income-tax Act, 1961.
(3.) The impugned order which is set out at annexure " K " to the writ petition, inter alia, runs as follows : " The Board regret their inability to accord approval under Section 80-O of the Income-tax Act, 1961, to the above-mentioned agreement, inter alia, for the reason that the loaning of the services of engineers and draughtsmen for service abroad is not a technical service as contemplated under Section 80-O of the Act. ";