2004 (9) TMI 53

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....e Income-tax Appellate Tribunal in I.T.A. No. 192/Mds of 1992 dated October 22, 1998, by formulating the following substantial question of law: "Whether, on the facts and in the circumstances of the case, the Appellate Tribunal is correct in law in allowing the deduction of Rs. 1,20,000 paid to Southern Technical Services (P.) Ltd. as consultancy fee under section 37 of the Income-tax Act, 1961?"....

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....nd it cannot be said to be outside the purview of the business of the company. We are of the considered opinion that the contention of the assessee cannot be rejected merely on the reason that the very same service can be obtained from various sources easily as contended by learned counsel for the Department. The reasoning given by the Tribunal is perfectly in conformity with the provisions of se....