Allowing the appeal of the  revenue , the Tribunal held that ,the Portfolio Management Fees and Performance Linked Fees were paid by the assessee to his portfolio manager towards service charges for making investments of his funds and managing the portfolioof securities, therefore, the same not being an expenditure incurred wholly and exclusively in connection with the transfer of the shares out of which STCG had arisen to the assessee,  is not allowable as a deduction. ( Referred , Devendra Motilal Kothari v. Dy. CIT [2011] 132 ITD 173 (Mum) (Trib), Dy. CIT v. KRA Holdings and Trading (P.) Ltd. [2012] 54 SOT 493 (Mum) (Trib) CIT v. Shakuntla Kantilal (Smt.)  [1991]190 ITR 56 (Bom) (HC)    Pradeep Kumar Harlalka v. A CIT [2011] 47 SOT 204 (URO) (Mum.), (Trib ,CIT v. Roshanbabu Mohammed Hussein Merchant [2005]275 ITR 231( Bom( HC)  Homi K. Bhabha v. ITO (IT) [2011] 48 SOT 102 (Mum) (Trib) )( AY.2007-08)