JUDGMENT judgment of court was delivered by R. Sudhakar J.-The above tax case (appeals) are filed by Revenue as against order of Income-tax Appellate Tribunal raising following substantial questions of law: T. C. (A.) No. 1019 of 2014 Whether, on facts and in circumstances of case, Income-tax Appellate Tribunal was right in holding that foreign travel expenses incurred towards wife of partner is allowable deduction? T. C. (A.) No. 1020 of 2014 Whether, on facts and in circumstances of case, Income-tax Appellate Tribunal was right in holding that foreign travel expenses incurred towards Adirano Nathalini and others are allowable deduction even though no business connection was proved ?" respondent-assessee, partnership firm, is engaged in manufacturing of leather shoe uppers. assessee filed its return of income for assessment years 2005-06 and 2007-08 admitting total income of Rs. 1,08,20,770 and Rs. 24,99,170, respectively. return of income for assessment year 2005-06 was processed under section 143(1) of Income- tax Act. Later on, said assessment was reopened under section 147 of Income-tax Act and notice under section 148 of Income-tax Act was issued to assessee. authorised representative of assessee objected to reopening of assessment stating that foreign travel expenses have been incurred to bring buyers to India as it is practice in this trade. Assessing Officer, while completing assessment for both assessment years, not satisfied with explanation of assessee, disallowed assessee's claim on foreign travel expenses spent on wife of partner of firm and also on others. Aggrieved by said order of assessment, assessee preferred appeals before Commissioner of Income-tax (Appeals). Commissioner of Income-tax (Appeals) found that during financial year 200405, assessee incurred foreign travel expenses and tax audit report revealed that expenses are personal in nature. Commissioner of Income-tax (Appeals) further found that assessee's wife is neither partner nor employee of assessee-firm. Therefore, Commissioner of Income-tax (Appeals) held that assessee failed to establish business connection with travelling expenses of wife of partner. Accordingly, Commissioner of Income-tax (Appeals) dismissed appeals holding that in absence of any details, it is very difficult to believe assessee's explanation. Aggrieved by order of Commissioner of Income-tax (Appeals), assessee preferred further appeals before Income-tax Appellate Tribunal. It is seen from order of Tribunal that assessee is shoe company and has been issued with certificate of exporter/importer code. On perusal of partnership deed, Tribunal found that said partnership deed revealed that assessee-firm came into existence on July 1, 1993, and Smt. Ravia Aejaz was one of founder partners. Tribunal took on record said document and held that said Mrs. Ravia Aejaz had travelled in capacity of partner herself of assessee-firm, which is importer/exporter of shoe products and, hence, expenses incurred by said person is wholly and exclusively for purpose of business. For assessment year 2007-08, Tribunal held that no cogent reason was cited to disallow assessee's claim. Hence, foreign travel expenses incurred to Adirano Natalini along with other persons are wholly and exclusively for purpose of business. Accordingly, Tribunal allowed appeals filed by assessee. Aggrieved by order of Tribunal, Revenue has filed present appeals before this court. Learned standing counsel appearing for Revenue reiterating findings of Assessing Officer and Commissioner of Income-tax (Appeals) submits that assessee has not established business connection with travelling expenses of wife of partner. In support of his contention, he placed reliance on decision of this court in D. B. Madan v. CIT reported in [2003] 261 ITR 193 (Mad), wherein it was held that if object of foreign tour by assessee's wife was to attend on assessee and for his personal comforts, expenditure would not qualify for deduction though result of such expenditure may increase efficiency of assessee in attending to his business. He further submits that wife of assessee herein was not associated with firm of assessee and she was not partner of firm. Hence, order of Tribunal may be set aside. Heard learned standing counsel appearing for Revenue and perused materials placed before this court. On perusal of order of Tribunal, we find that as per partnership deed, wife of assessee was one of partners of firm. Hence, Tribunal was justified in granting benefit to assessee on basis of partnership deed. We find no reason to discredit finding of fact, more so, after perusing assessment order passed under section 143(3) read with section 147 of Income-tax Act, which contains no reason as to why it should not be treated as business income. mere ipse dixit of officer is not ground to deny claim made by assessee. reliance placed by learned standing counsel appearing for Revenue on decision in D. B. Madan v. CIT reported in [2003] 261 ITR 193 (Mad) is distinguishable on facts. facts therein is that wife of assessee therein had travelled along with her husband citing health ground and was not associated with company either as partner or in any other official capacity. In present case, wife is partner of assessee-firm as per partnership agreement. Hence, expenses incurred towards foreign travel of wife of assessee along with other persons should be treated as expenditure incurred wholly and exclusively for purpose of business. In view of above, we see no question of law much less any substantial question of law arises for consideration in these appeals. Accordingly, both appeals are dismissed. No costs. Consequently, M. P. No. 1 of 2014 is also dismissed. *** Commissioner of Income-tax v. Irbaz Shoe Co