Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
The HC dismissed the miscellaneous application and upheld the ITAT's remand to the AO/TPO/DRP, holding that whether the assessee qualifies as a trader other than a wholesale trader depends on factual satisfaction of the two cumulative conditions in the CBDT notification dated 29.10.2015. The court observed the assessee had adduced material showing non-compliance with one condition and the ITAT had already accepted non-classification as a wholesale trader for AY 2014-15; consequently the issue is fact-centric and does not raise any substantial question of law, precluding judicial interference with the remand or directing application of a 3% tolerance.
The HC dismissed the miscellaneous application and upheld the ITAT's remand to the AO/TPO/DRP, holding that whether the assessee qualifies as a trader other than a wholesale trader depends on factual satisfaction of the two cumulative conditions in the CBDT notification dated 29.10.2015. The court observed the assessee had adduced material showing non-compliance with one condition and the ITAT had already accepted non-classification as a wholesale trader for AY 2014-15; consequently the issue is fact-centric and does not raise any substantial question of law, precluding judicial interference with the remand or directing application of a 3% tolerance.
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