4.The assessee filed its return of income for the assessment year 1990-91 declaring total income of Rs.82,390/- on 11.01.1991. The case was selected for scrutiny, in response to which the assessee's authorized representative and the Director appeared before the Assessing Officer and answered the queries raised by the Assessing Officer. The Assessing Officer noted that the main source of income of the assessee Company is by way of service charges received from its clients mainly from Corporate Sector for providing financial services like arranging credits investment advise, etc. For the previous year relating to the assessment year 1990-91, the assessee had admitted a gross receipt of service charges amounting to Rs.17,69,638.65. It also claimed payment of service charges amounting to Rs.5,02,077.70 and the net amount of Rs.12,67,560.95 was shown in the Profit and Loss Account. The assessee claimed payment of service charges to ten persons/firms. The Assessing Officer disbelieved the payment of such service charges and for which purpose, the assessee was called upon to furnish the names of those ten persons. Upon the names being furnished, the said persons were summoned and statement under Section 131 was recorded. After going through the statements given by those ten persons, the Assessing Officer found that none of the parties have rendered any worthwhile service to the assessee Company and most of them did not have any knowledge about their own business and did not know for what purpose they received money from the assessee. Accordingly the stand taken by the assessee was rejected and the assessment was completed by order dated 22.03.1993. The assessee carried the matter by way of an appeal to the Commissioner of Appeals-IV (CITA), Madras, who by order dated 28.02.1995 confirmed the factual finding recorded by the Assessing Officer and on further appeal before the Tribunal, the order passed by the Assessing Officer and the CIT(A) was
