Bench: Honourable The Chief Justice Honourable Mrs. Justice Susmita Phukan Khaund Judgment Date : 02-08-2023 (S.P. Khaund, J) 1. Heard Mr. S. Chetia, Learned Senior Standing Counsel, Income Tax Department & Mr. G.N. Sahewalla, Learned Senior Counsel For The Respondent Assisted By Learned Counsel Mr. M. Sahewalla. 2. This Is An Appeal U/S 260A Of Income Tax Act, 1961 (The I.T. Act For Short) Against The Order Dated 14.11.2018 Passed By The Income Tax Appellate Tribunal ‘E’ Court

7. The AO, in order to verify the correctness of submissions summoned the 8 Naga parties and the Proprietor of M/s Meitei Sri Mohendra Singh Lurembam produced four sub- contractors and their statements were recorded. The Investigation Wing (AO) held that the respondent’s claim that the contract work was executed by individuals belonging to the scheduled tribes