TMI Blog2022 (2) TMI 500X X X X Extracts X X X X X X X X Extracts X X X X ..... Court finds that the Tribunal as the last fact finding authority has held that the Revenue had failed to establish that the said activities had been undertaken by the Respondent only in the Assessment Year under consideration. In fact, the said activities have been undertaken by the respondent right from the year 2007-08. A perusal of the paper book also reveals that for the earlier and subsequ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sent case. - ITA 137/2021 - - - Dated:- 7-2-2022 - HON'BLE MR. JUSTICE MANMOHAN HON'BLE MR. JUSTICE NAVIN CHAWLA Appellant Through Mr. Abhishek Maratha, Sr. Standing Counsel. Respondent Through None J U D G M E N T : (Oral) MANMOHAN, J C.M.No.27246/2021 Keeping in view the averments in the application, the delay of 47 days in filing the appeal is c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... counsel for the Appellant submits that the Tribunal erred in overlooking the fact that the act of transfer of the management and control of Rajan Dhall Hospital, Vasant Kunj, Delhi vide 'Operational and Management Agreement with M/s Fortis Hospital Pvt. Ltd. existing absolutely for commercial purposes is violative of Section 11 of the Act. 6. Upon a perusal of the paper book, this Court fin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2014-15. However, at that stage, learned counsel for the Appellant had prayed for some time to obtain instructions and file additional documents. 9. Though, learned counsel for the Appellant states that he has filed the additional documents, however, the same are not on record. In any event, in view of the principle of consistency and uniformity, this Court is of the view that no substantial q ..... X X X X Extracts X X X X X X X X Extracts X X X X
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