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of <h1>Charitable Trust Wins Partial Relief in Demonetisation Cash Deposit Dispute, Case Remanded for Detailed Verification</h1> ITAT Cochin partially allowed a charitable trust's appeal regarding cash deposits during demonetisation. The tribunal remanded the case to the Assessing ... Denial of exemption u/s 10(23C)(iiiad) - treating the cash deposits in SBN during the demonetisation period as unexplained money of the appellant trust - HELD THAT:- The facts as emanate from the record are that the appellant is a trust running education institutions. The explanation offered by the appellant trust in support of cash deposits that the cash deposits in SBN were made out of fees collection from students cannot be ruled out. AO had no occasion to examine the veracity of the explanation filed before the CIT(A) and, therefore, remand the matter back to the file of the AO to examine the veracity of explanation tendered in support of the cash deposit during demonetisation period by examining the records, as may be produced before him in support of such explanation. Appeal filed by the assessee stands partly allowed. The Appellate Tribunal (ITAT Cochin) heard an appeal by a charitable trust against the CIT(A)'s order confirming the AO's treatment of substantial cash deposits in Specified Bank Notes (SBN) during the demonetisation period as unexplained money for AY 2017-18. The appellant, running educational institutions and claiming exemption under section 10(23C)(iiiad) of the Income Tax Act, 1961, argued that the deposits represented fees collected from students, authorized by Government notifications, and contended that section 115BBE was inapplicable.The Tribunal identified the key issue as whether the AO was justified in treating the cash deposits as unexplained. Noting that the AO had not examined the veracity of the appellant's explanation, the Tribunal remanded the matter to the AO for a detailed inquiry into the records supporting the explanation for the SBN deposits. The Tribunal thus 'partly allowed' the appeal, directing further examination rather than outright acceptance or rejection of the AO's findings.
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