Binding administrative guidance requires consideration in purchase-tax assessments; unexamined tax determinations cannot stand and require fresh reconsideration.

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....Section 194Q compliance assessments must address Circular No. 13/2021, which provides guidelines for removing difficulties in applying tax deduction requirements to business purchases. A determination concerning alleged non-deduction that does not examine the circular's relevance cannot be sustained. The assessment must therefore be set aside and reconsidered by the assessing authority in light of the circular and applicable law.....