Categorical finding of fact by ITAT cannot be challenged as a substantial question of law

PCIT Vs NVP Venture Capital India Pvt. Ltd (Bombay High Court) On going through the order of the ITAT it is quite clear that the findings given therein are purely based of the facts placed before it. The facts, as placed before the ITAT, have not been controverted or denied by the revenue before us. The ITAT, after considering all these factual aspects, came to a categorical finding that Motilal Oswal Investment Advisors Pvt. Ltd. was engaged in a qualitatively different and diversified business than that of the assessee which was confined to rendering only non-binding investment advisory ser...