The assessee claimed exemption under s. 10(26) for AY 2016–17. He had not filed his return of income despite being allotted PAN wherein his address was shown as Mumbai. In proceedings initiated under s. 144, the assessee failed to produce material to establish that he satisfied the three statutory conditions under s. 10(26), namely (i) that he belonged to a Scheduled Tribe, (ii) that he was residing in the specified area (Ladakh region), and (iii) that the income claimed as exempt was derived from a source in such specified area. Though an ST certificate dated 17-5-2019 was furnished, no evidence was produced to prove residence in Ladakh during the relevant year or that the bank deposits represented income derived from sources in the specified area. A resident certificate issued subsequently in February 2022 was held insufficient to establish residence during the relevant assessment years. The AO completed the assessment denying exemption; the revision petition under s. 264 was dismissed by the PCIT concurring with the AO’s factual findings. On writ, the High Court held that satisfaction of the conditions under s. 10(26) is a question of fact to be determined on evidence. The assessee, having failed to prove residence in the specified area and nexus of income with such area, was not entitled to exemption. In view of concurrent findings of fact by two authorities, no interference was warranted under Art. 226. Writ petition dismissed. (AY. 2016–17)