Drawings/designs supply and erection supervision fees from German contractor: designs non-taxable; supervision taxed as FTS/PE depending on six-month ...
Imported analyser diagnostic cartridges treated as accessories with analyser system, not standalone diagnostic reagents; extended limitation and penal...
Steel-timber construction shuttering/formwork tariff classification dispute: essential character held steel, classified as shuttering under Heading 73...
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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