Section 263 Inadequate inquiry by AO, cannot be considered as lack of inquiry

Fusion Voice Solutions India (P) Ltd. Vs ITO (ITAT Visakhapatnam)  Evidently there was no principal agent relation, which warranted compliance of section 194H. Moreover, AO had called details of ledger accounts and salaries paid to employees during assessment under section 143(3); therefore, he had made inquiry in this regard. Not examining the entire transaction and sales by the assessee company to its retail dealers at best could be treated as inadequate enquiry but not lack of enquiry. Lack of enquiry is a reason for taking up the case for revision under section 263 but the inadequate enqu...