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    <description>Appellate authorities may entertain a fresh tax claim not raised before the Assessing Officer if the factual foundation is available, and the assessee succeeded on that point. Payments made under a voluntary retirement scheme were treated as revenue expenditure in line with binding precedent, with the issue decided against the Revenue. Delayed payment of employees&#039; contribution to provident fund was also treated as deductible according to settled authority, and no contrary factual or legal basis was shown. On these issues, no substantial question of law arose, and the Revenue&#039;s appeal failed.</description>
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      <description>Appellate authorities may entertain a fresh tax claim not raised before the Assessing Officer if the factual foundation is available, and the assessee succeeded on that point. Payments made under a voluntary retirement scheme were treated as revenue expenditure in line with binding precedent, with the issue decided against the Revenue. Delayed payment of employees&#039; contribution to provident fund was also treated as deductible according to settled authority, and no contrary factual or legal basis was shown. On these issues, no substantial question of law arose, and the Revenue&#039;s appeal failed.</description>
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