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...
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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