Ambulance-based emergency medical services were treated as a...

Ambulance-based emergency medical services were treated as a professional service, not a mere carriage or works contract, because the ambulances were specially equipped and staffed to provide treatment and monitoring during the critical initial period; tax was therefore deductible under section 194J, and the plea based on acceptance of section 194C treatment in an earlier year failed because each assessment year is separate and res judicata or estoppel does not apply in income-tax proceedings. The classifications for the HLL and FSMS contracts were set aside because the contractual terms and the assessee's submissions were not properly examined, requiring fresh consideration by the Assessing Officer.