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    <title>1984 (7) TMI 108 - ITAT BOMBAY-B</title>
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    <description>Section 52(2) cannot be invoked to substitute declared sale consideration for capital gains merely because the property is valued higher, unless there is material showing that more than the declared amount was actually received. Gratuity paid under a company scheme, even where some technical qualifying conditions were not fully met, was treated as deductible business expenditure because the payments were made uniformly for business purposes. Festival gifts were not treated as advertisement expenditure where they were aimed at maintaining business relations rather than attracting customers. Processing activity was sufficient to support industrial company status, and director-employee remuneration was governed by the provision found more favourable to the assessee. Secret commission and sales promotion were allowable when supported by regular records, trade practice, and business probability.</description>
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