SHANTI DEVI HISARIA,SITAMARHI vs. ITO, CENTRL CIR-2, PATNA

ITA 265/PAT/2025Status: DisposedITAT Patna21 July 2026AY 2020-218 pages
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What did the Tribunal hold?

The Tribunal held that the addition of Rs. 8,46,000/- made in AY 2020-21 was not justified as the jewellery was found from a locker operated on 26.08.2020, which falls in AY 2021-22. The Tribunal also dismissed several legal grounds raised by the assessee.

What were the facts?

A search and seizure operation was conducted, and subsequently, the assessee filed a return of income. During the assessment proceedings, jewellery and coins valued at Rs. 8,46,000/- were found in a locker operated on 26.08.2020. The Assessing Officer added this amount to the assessee's income for AY 2020-21.

What were the issues?

Whether the addition of jewellery and coins found in a locker operated in AY 2021-22 could be made in AY 2020-21. Whether the assessment proceedings were vitiated by procedural defects in issuing notices and obtaining approvals.

Which sections of the Income-tax Act were involved?

Section 132,Section 153A,Section 143(3),Section 153D,Section 127,Section 143(2),Section 69,Section 156,Section 139(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SMC BENCH, PATNA

For Respondent: Shri Ravi Kant Chowdhary, Sr. DR
Hearing: 01.07.2026Pronounced: 21.07.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

This is an appeal filed by the assessee against the order passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Ld. Commissioner of Income Tax (Appeals), Patna-3 [hereinafter referred to as “the Ld. CIT(A)] dated 25.03.2025 DIN & order No.

2 Shanti Devi Hisaria ITBA/APL/S/250/2024-25/1075014442(1) on the following grounds of appeal:

“1. FOR THAT on a true and proper interpretation of the scope and ambit of the provisions of s. 132 read with s.153A of the Income Tax Act, 1961, the Ld. Commission

The order continues below.

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