Is a party-and-party bill of costs accepted without a receipt?

Canada (Federal), Canada

The following excerpt is from Lundbeck Canada Inc. v. Canada (Health), 2014 FC 1049 (CanLII):

The Court decision in Teledyne confirms the authority of the assessment officer while further stating that not all expenditures need to be supported by a receipt: 23 In the taxation of a party-and-party bill of costs acceptance without inquiry of the propriety of a disbursement is wrong in principle and should be reviewed: vide IBM v. Xerox, supra at p. 186. Of course, all disbursements, even when properly expended, should be proved to the satisfaction of the Taxing Officer. But it does not follow that all items of expenditure should rigorously be supported by a receipt from the payee. There are other ways to prove that a bill has been paid. In my view, the prothonotary was perfectly right in allowing those costs as they were obviously incurred, and properly so, in connection with the various examinations for discovery. The entire amount is therefore taxable.

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