NIRMAL PURI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 26, NEW DELHI
What did the High Court hold?
The High Court dismissed the appeal filed under Section 260A of the Income Tax Act, holding that no substantial question of law arose for consideration. The Court noted that the addition made in the hands of the appellant pertained specifically to the value of the gold bars, which were treated as unexplained by the revenue authorities. The Court found no reason to interfere with the concurrent findings of the lower authorities on this specific aspect. The appeal was dismissed, and the pending application was also disposed of.
What were the facts?
The assessee, Nirmal Puri, challenged the concurrent findings of the revenue authorities regarding the treatment of a small quantity of bullion. The Assessing Officer (AO), vide order dated 29.03.2022, treated 426 grams of gold as unexplained and made an addition to the assessee's income. This addition was upheld by the Commissioner of Income Tax (Appeals) on 16.07.2025 and subsequently by the Income Tax Appellate Tribunal (ITAT) on 23.12.2025. The assessee argued that the total gold found in her locker was 1242 grams, including ornaments belonging to her and her daughter-in-law, which she contended was not excessive. The revenue countered that the unexplained portion specifically related to four gold bars of 24-carat, not gold jewellery.
What were the issues?
1. Whether the authorities below erred in concurrently treating a small quantity of bullion (426 grams) as unexplained, contrary to the assessee's submissions (Question of mixed law and fact, concerning the determination of unexplained income under the Income Tax Act). Assessee's Contention: The assessee argued that the 426 grams of gold treated as unexplained was a small quantity and that the total gold found in her locker (1242 grams), including ornaments, was not excessive. She contended that in an Indian family setup, a woman receives gold from various family members. The assessee relied on the principle that reasonable quantities of gold, especially in the hands of a woman, should be considered explained. Revenue's Contention: The revenue argued that the authorities had concurrently held against the appellant. It was specifically pointed out that the addition pertained to four gold bars of 24-carat, which were treated as unexplained, while the gold ornaments were duly explained and no addition was made in respect of them.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Cause title — parties, addresses and appearances
O R D E R % 21.07.2026
Learned counsel for the appellant argued that the authorities below have erred in rejecting concurrently treating the small quantity of bullion (426 grams) to be unexplained.
Learned counsel for the appellant further argued that the appellant/assessee is 70 year old lady, residing with her family and that in a family set-up in an Indian society, a lady receives gold ornaments and jewellery not only from her parents but also from her in-laws and other family members, including son apart from her husband.
He submitted that the total gold found in the locker was 1242 grams, including gold ornaments belonging to the appellant as well as her This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 23/07/2026 at 12:00:58
ITA 529/2026 daughter-in-law, which cannot be said to be excessive. Yet, the Assessing Officer vide order dated 29.03.2022 found 426 grams of gold to be unexplained and made an addition in the hands of the appellant. Such addition, despite the satisfactory explanation furnished by the appellant, was affirmed by Commissioner of Income Tax (Appeals) vide order dated 16.07.2025 so also by Income Tax Appellate Tribunal vide order dated 23.12.2025. 4. Mr. Gaurav Gupta, learned Senior Standing Counsel for the respondent, submitted that all the authorities have concurrently held against the appellant. He pointed out that what was found in appellant’s locker was 4 gold bars of 24-carat and not gold jewellery. He pointed out that the authorities have treated the gold bars to be unexplained, while the ornaments have been held duly explained and no addition in that regard was made in the hands of the appellant/assessee.
Having heard learned counsel for the parties and considering the fact that the addition made in the hands of the appellant pertains to the value of the gold bars, we are of the view that no interference is warranted in the appeal that has been filed under Section 260A of the Income Tax Act, as no substantial question of law arises for our consideration.
The appeal is dismissed along with pending application. DINESH MEHTA, J RAJNEESH KUMAR GUPTA, J JULY 21, 2026/nd This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 23/07/2026 at 12:00:58
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