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Contract expenditure was held to be allowable where the assessee substantiated the subcontract payments with a complete documentary trail, including the principal award, subcontracting documents, ledger accounts, confirmations, audited financial statements and bank statements. The Tribunal noted that the Assessing Officer and the Commissioner (Appeals) had not rebutted these materials or made any independent verification from the concerned parties. Since the Revenue had accepted the contract receipts as income, it could not deny the corresponding expenditure on the same factual matrix. The assessee was found to have discharged the onus, and the entire disallowance of subcontract expenses was deleted.
Contract expenditure was held to be allowable where the assessee substantiated the subcontract payments with a complete documentary trail, including the principal award, subcontracting documents, ledger accounts, confirmations, audited financial statements and bank statements. The Tribunal noted that the Assessing Officer and the Commissioner (Appeals) had not rebutted these materials or made any independent verification from the concerned parties. Since the Revenue had accepted the contract receipts as income, it could not deny the corresponding expenditure on the same factual matrix. The assessee was found to have discharged the onus, and the entire disallowance of subcontract expenses was deleted.
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