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    <title>2024 (10) TMI 71 - ITAT  AHMEDABAD</title>
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    <description>Where the attribution of hostel receipts and cash deposits was not satisfactorily established on the record, and the exemption claim under section 10(23C)(iiiad) had not been properly examined, the Tribunal considered fresh factual inquiry necessary. The material did not conclusively show the relationship between the trust, the receipts and the persons said to have offered the income in their own returns. As a result, the additions and exemption claim were not finally decided on merits and the matter was restored to the first appellate authority for de novo consideration after giving the assessee an opportunity to produce supporting evidence.</description>
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      <link>https://www.taxtmi.com/caselaws?id=759472</link>
      <description>Where the attribution of hostel receipts and cash deposits was not satisfactorily established on the record, and the exemption claim under section 10(23C)(iiiad) had not been properly examined, the Tribunal considered fresh factual inquiry necessary. The material did not conclusively show the relationship between the trust, the receipts and the persons said to have offered the income in their own returns. As a result, the additions and exemption claim were not finally decided on merits and the matter was restored to the first appellate authority for de novo consideration after giving the assessee an opportunity to produce supporting evidence.</description>
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