2007 (8) TMI 43

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.... 'C' in ITA No.5278/Del/96 relevant for the block assessment years 1995-96 and 1996-97. 2. The first issue urged by the Revenue in the present appeal is withregard to payment of a sum of Rs.93,10,418/- to one Ms. Magda towardsconsultancy fees by the Assessee out of which an amount of Rs.66,07,193/- wasdisallowed by the Assessing Officer but allowed by the Income Tax AppellateTribunal. 3. The....

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.... of the contract. He restricted the deduction in respect of this payment to 3% of the contract value. He rejected the contention of the Assessee that the entire amount paid to Ms. Magda   was expended for business purposes. 4. The Assessee appealed to the Tribunal which in the impugned order accepted the contention of the Assessee. The Tribunal has noted in its order that the same Ass....

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....e amount paid to Ms. Magda could not be said to be the undisclosed income of the Assessee. 6.We also find that the amount was expended for the business purposes of the Assessee and this is a finding of fact rendered by the Tribunal. There is no material to suggest on the contrary. 7. In our opinion, no substantial question of law arises from the first issue urged by the Revenue in regard to ....