Revisionary jurisdiction cannot replace a completed inquiry merely because a broader factual verification is later preferred.
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....Revisionary jurisdiction cannot be invoked merely because a more extensive enquiry is preferred where the Assessing Officer has examined the deduction claim, obtained the statutory audit report and employee-wise details, issued a proposed disallowance notice, and considered the response. Revision requires an erroneous assessment that is prejudicial to Revenue, not simply an allegedly inadequate enquiry. Deduction eligibility is not denied solely because a staffing employer deploys workers at client premises, where it recruits, appoints, pays, reassigns and fulfils statutory employment obligations. Client supervision and salary reimbursement alone do not displace the employer-employee relationship. On these facts, revision for fresh examination was impermissible and the assessment was restored.....
TaxTMI