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Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
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Specific queries, recruitment details, employee-wise particulars, pay slips, compliance explanation and Form 10DA having been called for and placed on record, the assessment was not erroneous for want of enquiry merely because the order lacked elaborate discussion; revision under section 263 was therefore unwarranted. The Principal Commissioner also failed to identify any further enquiry that was specifically necessary. On the deduction issue, amalgamation did not enlarge the assessee's own claim or increase the employees counted for that claim, so the business-reorganisation bar could not be invoked to deny the additional employee cost deduction examined in assessment.
Specific queries, recruitment details, employee-wise particulars, pay slips, compliance explanation and Form 10DA having been called for and placed on record, the assessment was not erroneous for want of enquiry merely because the order lacked elaborate discussion; revision under section 263 was therefore unwarranted. The Principal Commissioner also failed to identify any further enquiry that was specifically necessary. On the deduction issue, amalgamation did not enlarge the assessee's own claim or increase the employees counted for that claim, so the business-reorganisation bar could not be invoked to deny the additional employee cost deduction examined in assessment.
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