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Pr. Commissioner Of Income Tax (Tds)-2 vs National Health & Education Society on 22 February, 2019 cites

The Commissioner Of Income Tax (Tds), ... vs Grant Medical Foundation ( Rub Y Hall ... on 22 January, 2015

13. On the other hand, Mr. Tiwari, the learned Advocate appearing on behalf of the assessee took us through the impugned orders and submitted that the ITAT correctly analysed all the provisions and thereafter came to the conclusions that it did. He submitted that as far as Question (a) is concerned, the same is fully covered by a decision of this Court in the case of the Commissioner of Income-tax (TDS), Pune vs. Grant Medical Foundation (Ruby Hall Clinic) [ITXA No.140 of 2013 decided on 22nd January, 2015]. As far as Questions (b), (c) and (d) are concerned, he submitted that no substantial question of law arises since the findings in relation thereto were purely factual in nature. The ITAT is the last fact finding authority and unless it is shown that these findings (based on the facts) of the ITAT are completely perverse, there is no occasion for any substantial question of law arising therefrom. In this regard, Mr. Tiwari took us through the findings given by the ITAT and urged that all these findings are based purely on facts which required no interference and certainly did not suffer 9/19 itxa-105-16_5.doc ::: Uploaded on - 22/02/2019 ::: Downloaded on - 21/03/2019 00:10:08 ::: from any perversity which in turn would give rise to any substantial question of law. As far as Question (e) is concerned, Mr. Tiwari submitted that considering the findings given by the ITAT, this question has become purely academic which need not be considered by us in this case and could be kept open to be considered in an appropriate case where the issue would be alive and would have a direct bearing on the outcome of the case. For all the aforesaid reasons, Mr. Tiwari submitted that all the above appeals therefore do not give rise to any substantial question of law and consequently, all the appeals be dismissed.
Bombay High Court Cites 51 - Cited by 23 - S C Dharmadhikari - Full Document
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