In the result, both the revenue appeals ITA No
Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh
12A and section 11 of the Act, by holding that the assessee was entitled for the exemption on income determined u/s 68 of the Act. Revenue has vehemently argued that exemption u/s 11 cannot be allowed on a different head as unexplained/unsecured loans taxed u/s 68 cannot be pegged to any other head of income including income from other sources