JIGNA KUNDAN BHATT,VIRAR vs. DCIT, CENTRAL CIRCLE 1(1), MUMBAI, MUMBAI

ITA 5265/MUM/2025Status: DisposedITAT Mumbai29 December 2025AY 2020-21Bench: SMT. BEENA PILLAI (Judicial Member)15 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee discharged the onus under Section 68 by providing loan confirmations, ITRs, and bank statements of lenders, and deleted the addition. It also held that the jewellery found was within reasonable limits for a joint family, considering CBDT instructions and judicial precedents, and deleted that addition as well.

What were the facts?

The assessee received unsecured loans and had jewellery found during a search. The Assessing Officer treated the loans as unexplained cash credit and the jewellery as unexplained investment. The CIT(A) partially deleted the addition on loans but confirmed the jewellery addition.

What were the issues?

Whether the assessee discharged the onus under Section 68 for unsecured loans, and whether jewellery found during a search can be treated as unexplained investment despite family ownership claims and CBDT instructions.

Which sections of the Income-tax Act were involved?

Section 68,Section 69A,Section 132,Section 133(6),Section 131

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(5)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, “F” BENCH MUMBAI

For Appellant: Shri Subhodh Ratnaparkhi, Ld. AR
For Respondent: Ms. Kavitha Kaushik, Ld. DR
Hearing: 11.12.2025Pronounced: 29.12.2025

PER MAKARAND VASANT MAHADEOKAR, AM: This appeal is filed by the assessee against the order passed by the Commissioner of Income-tax (Appeals)-47, Mumbai [hereinafter referred to as “CIT(A)”], dated 24.06.2025, for Assessment Year 2020–21, arising out of the assessment order passed under section 143(3) of the Income-tax Act, 1961

2 Jigna Kundan Bhatt

[hereinafter referred to as “the Act”] by the Assistant Commissioner of Income-tax, Central Circle-1(1), Mumbai, dated 28.09.2021. 2. The facts of the case are that assessee is an individual. For the year under consideration, the assessee filed her return of income on 05.02.2021 dec

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 68

All 29,931 judgments and leading authorities on Section 68 →

Recent GST High Court judgments

Search GST case law →