Dismissing the appeals of the assessee , the Court held that the principle of consistency or doctrine of precedents would not apply in the present facts, as undisputedly there was a change in law. The Tribunal on the facts found that the routine services were rendered in India and not from India. S. 80-O very clearly restricts the benefit of deduction thereunder to the extent technical services are rendered from India. The routine services were undisputedly services such as supervising, loading, unloading, and storage rendered in India and not outside and/or from India. Routine services such as supervising, loading and storage of goods, even if they required a high degree of technical know-how and experience, would still be services rendered in India and not services rendered from India. Consequently, they would be hit by Explanation (iii) to S. 80-O . Accordingly the fees for routine services were not entitled to special deduction under S. 80-O .( AY. 1992 -93 ,1994 -95 to 1997 -98)