9911796707
TMI Blog2025 (1) TMI 1184X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Act dated 24.03.2022. 2. The Revenue is in appeal before the Tribunal raising the following grounds of appeal: "1. That the Ld. CIT(A), NFAC, Delhi is not justified both in law and in fact, to allow exemption u/s. 10(26AAA) of the I.T. Act, 1961 to the assessee on addition treated as undisclosed income and unexplained income u/s 69A of the I.T. Act, 1961 and Unexplained Investment u/s 69 of the act allowing exemption u/s. 10(26AAA) of the I.T. Act on income which remained unexplained with regards to the sources of such income during the course of assessment proceedings. 2. That the Ld. CIT(A), NFAC, Delhi is not justified both in law and in fact, to delete the addition made by the Assessing Officer relying on fresh evidence whi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ame and style of M/s Nayuma Indane and DTH services. She is an authorized dealer of Indian Oil Corporation Limited and received commission income on DTH services from Dish Infra Services Private Limited in the district of Namchi, Sikkim. The assessment for AY 2017-18 was re-opened by the Ld. AO by issuing a notice to the assessee as the assessee had not filed the return of income and the assessee had made several financial transactions during the year. The assessee responded that she was exempted from income tax as per clause (26AAA) of section 10 of the Act and had been regularly paying the GST on other income vide GST No. 11BPVPRG1ZU. The details of Dish TV recharge where even the TDS was deducted regularly were also attached. The Ld. AO ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... corded in the register maintained under the Sikkim Subjects Regulation, 1961 read with the Sikkim Subject Rules, 1961 ("Register of Sikkim Subjects"), immediately before 26 April 1975; or * an individual, whose name is included in the Register of Sikkim Subjects by virtue of the Government of India Order No. 26030/36/90-I.C.I., dated the 7 August 1990 and Order of even number dated the 8 April 1991; or * any other individual, whose name does not appear in the Register of Sikkim Subjects, but it is established beyond doubt that the name of such individual's father or husband or paternal grandfather or brother from the same father ("close relatives") has been recorded in that register. The income of the appellant is hence exempt u/s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he purposes of this clause "Sikkimese" shall mean- (i) an individual, whose name is recorded in the register maintained under the Sikkim Subjects Regulation, 1961 read with the Sikkim Subject Rules, 1961 (hereinafter referred to as the "Register of Sikkim Subjects"), immediately before the 26th day of April, 1975; or (ii) an individual, whose name is included in the Register of Sikkim Subjects by virtue of the Government of India Order No. 26030/36/90-I.C.I., dated the 7th August, 1990 and Order of even number dated the 8th April, 1991; or (iii) any other individual, whose name does not appear in the Register of Sikkim Subjects, but it is established beyond doubt that the name of such individual's father or husband or paternal gra ..... X X X X Extracts X X X X X X X X Extracts X X X X
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