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    <description>Rule 27 permits a respondent before the Tribunal to support the appellate order on a ground decided against it, even without filing a cross-objection, and the assessee was entitled to rely on that route to defend the relief granted below. Portfolio management service fees incurred by a non-banking financial company for managing its investment business were genuine business outgoings, and were held allowable as expenditure laid out wholly and exclusively for business purposes rather than capital outlay or an inadmissible claim.</description>
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