Appeal partly allowed: wildlife eco-adventure tours not tour operator; accommodations not renting; training taxable; penalties and extended limitation...
ITAT set aside the impugned order of the CIT(A) and restored the matter to the file of the CIT(A) for de novo adjudication. The Tribunal noted that the joint development agreement was subsequently cancelled and no development was executed-facts central to whether a transfer occurred under section 2(24) read with the Transfer of Property Act-which the CIT(A) had overlooked. The CIT(A) is directed to afford the assessee an opportunity of hearing, to consider all documentary evidence tendered, and to decide the issue afresh by a reasoned, speaking order in accordance with law. Proceedings are remitted for reconsideration on these specified factual and legal aspects.
ITAT set aside the impugned order of the CIT(A) and restored the matter to the file of the CIT(A) for de novo adjudication. The Tribunal noted that the joint development agreement was subsequently cancelled and no development was executed-facts central to whether a transfer occurred under section 2(24) read with the Transfer of Property Act-which the CIT(A) had overlooked. The CIT(A) is directed to afford the assessee an opportunity of hearing, to consider all documentary evidence tendered, and to decide the issue afresh by a reasoned, speaking order in accordance with law. Proceedings are remitted for reconsideration on these specified factual and legal aspects.
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