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ITAT addressed exemption claim under section 10(26AAA) regarding unexplained cash withdrawals in FY 2017-18. While CIT(A) upheld AO's denial of Sikkimese exemption, it improperly admitted additional evidence under Rule 46A and classified deposits as contract income without giving AO hearing opportunity. Given new documentation presented at ITAT stage not previously available to AO, matter remanded for de novo assessment. ITAT clarified that for 10(26AAA) exemption, both Sikkimese status and Sikkim-sourced income must be established. Assessee permitted to present all relevant submissions supporting exemption claim during fresh assessment. Both assessee's and Revenue's appeals allowed for statistical purposes.
ITAT addressed exemption claim under section 10(26AAA) regarding unexplained cash withdrawals in FY 2017-18. While CIT(A) upheld AO's denial of Sikkimese exemption, it improperly admitted additional evidence under Rule 46A and classified deposits as contract income without giving AO hearing opportunity. Given new documentation presented at ITAT stage not previously available to AO, matter remanded for de novo assessment. ITAT clarified that for 10(26AAA) exemption, both Sikkimese status and Sikkim-sourced income must be established. Assessee permitted to present all relevant submissions supporting exemption claim during fresh assessment. Both assessee's and Revenue's appeals allowed for statistical purposes.
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