Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Payment for independent contractor services for MIS reporting, stock verification and marketing were found to be business-necessary and allowable where rendered by unrelated and independent entities and supported by reports and inventory certificates; therefore the examiner's blanket disallowance based on perceived unreasonableness was rejected and books of account were not struck. Comparative per-location cost differences alone did not justify disallowance absent evidence of fictitiousness or lack of service, and the assessee's long experience and engagement terms were held relevant. The appellant's grounds to allow these contract expenses were accepted and the appeal was allowed.
Payment for independent contractor services for MIS reporting, stock verification and marketing were found to be business-necessary and allowable where rendered by unrelated and independent entities and supported by reports and inventory certificates; therefore the examiner's blanket disallowance based on perceived unreasonableness was rejected and books of account were not struck. Comparative per-location cost differences alone did not justify disallowance absent evidence of fictitiousness or lack of service, and the assessee's long experience and engagement terms were held relevant. The appellant's grounds to allow these contract expenses were accepted and the appeal was allowed.
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