Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of compensation paid for exchange rate loss was tested by analysing the contract and commercial expediency; the High Court found a contractual compensation clause and accepted genuineness of the payment, concluding the expenditure falls within business expenditure principles and should be allowed. The Tribunal's reversal based solely on absence of an express agreement clause was rejected, and the CIT(A)'s allowance on commercial expediency was restored, resulting in relief to the assessee on the tax disallowance.
Deductibility of compensation paid for exchange rate loss was tested by analysing the contract and commercial expediency; the High Court found a contractual compensation clause and accepted genuineness of the payment, concluding the expenditure falls within business expenditure principles and should be allowed. The Tribunal's reversal based solely on absence of an express agreement clause was rejected, and the CIT(A)'s allowance on commercial expediency was restored, resulting in relief to the assessee on the tax disallowance.
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