Prospective valuation amendment limits reassessment: unamended fair market value reference could not justify reopening based on a registered valuer's ...
Exemption for examination-related services rejected where recipients were commercial entities; suppression sustained extended limitation and penalties...
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Commodity-trading receivables written off as bad debts qualify for deduction where they were previously included in income and written off in the books; a possible future recovery does not justify disallowance. Characterising the transactions as speculative or the amount as capital investment does not displace fulfilment of those conditions. The bad-debt disallowance was deleted, subject to taxation of any later recovery in the year received. For windmill-profit deductions, head-office expenses and depreciation on common assets require factual examination of their components, use and allocation to eligible operations. That computation was remanded for fresh adjudication.
Commodity-trading receivables written off as bad debts qualify for deduction where they were previously included in income and written off in the books; a possible future recovery does not justify disallowance. Characterising the transactions as speculative or the amount as capital investment does not displace fulfilment of those conditions. The bad-debt disallowance was deleted, subject to taxation of any later recovery in the year received. For windmill-profit deductions, head-office expenses and depreciation on common assets require factual examination of their components, use and allocation to eligible operations. That computation was remanded for fresh adjudication.
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