Tribunal held that, merely because the payee is relative of promoter salary paid cannot be disallowed. AO cannot decide the reasonable and commercial expenditure. As regards payment to consultant    the assessee had filed the general sales agent agreement between the assessee-company and AE and the agreement appointing this company as the consultant. Apart from this, correspondence between AE and the hotel was submitted before the lower authorities. The Assessing Officer had not brought any material on record to show that no services were rendered by AE. Moreover, no tax was required to be deducted at source on the payment in view of articles 14(7) and 22(1) of the Double Taxation Avoidance Agreement between India and the U. A. E. The Commissioner (Appeals) observed that there was evidence to indicate that efforts were made by AE towards the fulfilment of the terms of the agreement and failure to procure business did not lead to the conclusion that the transaction was not genuine. (AY. 2011-12 to 2013-14)