Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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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