TMI Blog2007 (5) TMI 235X X X X Extracts X X X X X X X X Extracts X X X X ..... , for the respondent JUDGMENT The judgment of the court was delivered by V.B. GUPTA, J. - Admit. 2. In the present appeal, Revenue has raised two issues for our consideration. The first issue is as to whether the Income Tax Appellate Tribunal (for short as 'Tribunal') rightly allowed deduction of Rs.10,92,750/-to the Assessee on account of bad debts under Section 36(1)(vii) of the Income Tax Act, 1961 (for short as 'Act'). 3. The second issue is as to whether the Tribunal was correct in law in allowing deduction of remuneration of Rs.4,52,833/- paid by the Assessee to Shri. Neeraj Kanwar despite the fact that Assessee had not established rendering of services by Shri. Neeraj Kanwar for the purposes of business of the Asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... owable under Section 36(1)(vii) of the Act as bad debt and also allowed the claim of the Assessee with respect to remuneration of Rs.4,52,833/- paid to Shri. Neeraj Kanwar holding that looking to the educational profile of Shri. Neeraj Kanwar, it was adequately explained as justifiable. 7. The Revenue challenged the order passed by Commissioner of Income Tax (Appeal) before the Tribunal and the Tribunal vide impugned order dated 30 th December, 2005 upheld the order of Commissioner of Income Tax (Appeal) on both the issues. 8. Now, the Revenue has challenged the impugned order of the Tribunal by way of present appeal under Section 260A of the Act before this Court. 9. It has been contended by learned counsel for the Revenue tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... - on account of bad debts and we do not find any infirmity in the reasoning given by the Tribunal on this point and as such no substantial question of law with regard to this issue arises for our consideration and appeal filed by the Revenue on this ground stand dismissed. 13. With regard to the issue of allowing deduction of remuneration of Rs.4,52,833/- paid by the Assessee to Shri. Neeraj Kanwar, is concerned we are of the opinion that the following substantial question of law arises for our consideration:- "(1) Whether the Tribunal was justified in law in allowing deduction of remuneration of Rs.4,52,833/- paid by the Assessee to Shri. Neeraj Kanwar despite the fact that the Assessee had not established rendering of services by Sh ..... X X X X Extracts X X X X X X X X Extracts X X X X
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