Question raised before the High Court, whether on the facts and in the circumstances of the case and in law the Tribunal was justified in restoring the issue of addition on account of disallowance of collection charges retained by the airlines under Section 40(a)(ia) with respect to PSF(SC) when the said amount was not claimed by the appellant and when all the facts were already on record?.  Court held that passenger service fees (PSF) charges were withheld by Airlines Operators to extent of 2.5 per cent as per clause 1.4 of SOP issued by Ministry of Civil Aviation, no disallowance under section 40(a)(ia) could be made by department, in event, Airlines Operators had offered said 2.5 per cent in nature of payment made by way of commission, which was nothing but income to tax.  Verify  factual aspect, matter had to be restored to file of Assessing Officer.  (AY.  2011-12, 2012-13, 2013-14)