Dismissing the appeal of the assessee the Court held that the material available on record would clearly establish that the assessee had not obtained prior approval from the Reserve Bank

of India as contemplated under Explanations 1 and 2 to section 10B(3) of the Act. That apart, form 56G reflected that the foreign inward remittances with regard to the sale proceeds had not been brought into India in foreign currency during the previous year and within the six months period. Order of Tribunal is affirmed . ( AY. 2004-05)