POONAM CHAND RANWAKA,JAIPUR vs. ACIT CEN CIR-2, JAIPUR

IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “SMC” BENCH, JAIPUR BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER & SHRI T. R. SENTHIL KUMAR, JUDICIAL MEMBER ITA No. 65/JPR/2026 (Assessment Year:2023-24)

Poonam Chand Ranwaka Vs. ACIT 8A Govindi House, Central Circle 2 Kanota Bagh, Jaipur Jaipur �थायीलेखासं./जीआइआरसं./PAN/GIR No:AARPR 4844 C Appellant .. Respondent Appellant by : Sh. Harsh Poddar, Advocate Respondent by : Mrs. Aarti Rawat, Addl. CIT Date of Hearing 09.07.2026 Date of Pronouncement 21.07.2026 O R D E R Per Annapurna Gupta, AM:- The present appeal has been filed by the assessee against the order passed by the Office of the Commissioner of Income Tax Appeal CIT(A), Jaipur-04 (hereinafter referred to as “Ld. CIT(A)”), dated 09.01.2026 u/s 250 of the Income Tax Act, 1961, (hereinafter referred to as “the Act”).

P a g e | 2 ITA No.65/JPR/2026 Poonam Chand Ranwaka 2. The grounds raised by the assessee read as under:- 1. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in confirming the addition of Rs. 3,08,359/-out of Rs. 4,58,459/- u/s 69 on account of cash found during the course of search which was pin saving and out of cash withdrawal. 2. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in confirming the action of the Learned AO in applying the provisions of section 115BBE of the Income Tax Act, 1961. 3. The assessee craves your indulgence to add amend OR alter all OR any grounds of appeal before OR at the time of hearing 3. The solitary issue in the present appeal pertains to addition made to the income of the assessee on account of cash and silver jewellery found during search, the source of which allegedly remained unexplained. The AO had made addition of Rs.1,16,216/- on account of silver jewellery found and of Rs.4,58,459/- on account of cash found from the assessee, the source of which remained unexplained. 4. Orders of the Authorities below reveal that the assessee had explained that immediately before the search conducted on the assessee on 02.02.2023, there was the marriage of his son on 09.01.2023, and the cash and silver jewellery found was attributable to the gifts received on the occasion of marriage of the son. The same was rejected for non- substantiation of the said explanation with evidences. 5. We find no reason to confirm the addition. The assessee belongs to the JKD and PKD Group which was subjected to search action. The fact that there was marriage in the family a mere month before the search action took place, is not disputed. And gifts in cash and jewellery is quite common on the occasion of marriage. The amount of cash and jewellery found is too minuscule and can be easily attributed

P a g e | 3 ITA No.65/JPR/2026 Poonam Chand Ranwaka to the gifts received on the occasion of marriage of the son of the assessee. The additions therefore, made on account of cash and silver jewellery found, amounting of Rs.1,16,216 and Rs.4,58,459/- ,respectively are deleted. 6. In the result, the appeal of the assessee is allowed. Order pronounced in the open court on 21.07.2026

Sd/- Sd/- (T.R. Senthil Kumar) (Annapurna Gupta) JUDICIAL MEMBER ACCOUNTANT MEMBER Dated 21.07.2026 Mittali, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT By Order, Asst. Registrar ITAT, Jaipur