ANURADHA SETH,LUDHIANA PUNJAB vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3,, LUDHIANA PUNJAB

ITA 259/CHANDI/2025Status: DisposedITAT Chandigarh18 December 2025AY 2022-23Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)7 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the CIT(A)'s estimation of 50% of cash being spent on household expenses was arbitrary. While acknowledging that the purchase dates back to 2014 and no invoices were found, the Tribunal found the proven cash withdrawals sufficient to cover the purchase of 840 grams. The addition was restricted to 100 grams, valuing it at Rs. 4,89,000/-.

What were the facts?

A search and seizure operation was conducted on the Seth Cycle Group. During the search, gold jewellery weighing 3326.2 grams was found at the assessee's residence. The AO rejected the assessee's explanations for 1937.2 grams of gold jewellery and made an addition of Rs. 94,72,908/-. The CIT(A) granted partial relief, deleting additions for 521 grams and 450 grams, but confirmed the addition for 420 grams.

What were the issues?

Whether the CIT(A) was justified in restricting the benefit of unexplained jewellery purchase to 50% despite sufficient cash withdrawals and an affidavit filed by the assessee.

Which sections of the Income-tax Act were involved?

Section 132,Section 69B,Section 115BBE

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
आयकर अपीलीय अिधकरण,च"ीगढ़ "ायपीठ “ए” , च"ीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “ए”, CHANDIGARH HEARING THROUGH: PHYSICAL MODE "ी लिलत कुमार, "ाियक सद" एवं "ी कृणव" सहाय, लेखा सद" BEFORE: SHRI. LALIET KUMAR, JM & SHRI. KRINWANT SAHAY, AM आयकर अपील सं./ ITA No.259/Chd/ 2025 िनधा"रण वष" / Assessment Year : 2022-23 Auradha Seth बनाम The DCIT 65-D, Sarabha Nagar, Ludhiana Central Circle-3 Punjab-141002 Ludhiana "ायी लेखा सं./PAN NO: AQLPS4545D अपीलाथ"/Appellant ""थ"/Respondent िनधा"रती की ओर से/Assessee by : Shri Tej Mohan Singh, Advocate राज" की ओर से/ Revenue by : Shri Manav Bansal, CIT, DR सुनवाई की तारीख/Date of Hearing : 16/12/2025 उदघोषणा की तारीख/Date of Pronouncement : 18/12/2025

आदेश/Order PER LALIET KUMAR, J.M: This appeal filed by the Assessee is directed against the order of the Ld. Commissioner of Income Tax (Appeals)-5, Ludhiana [hereinafter referred to as ‘CIT(A)’], dated 06.01.2025, for the Assessment Year (AY) 2022-23. 2. The Assessee has raised the following grounds of appeal

1.

That the learned CIT(A) has wrongly confirmed the addition to the extent of Rs.20,53,800/- (out of total addition of Rs.94,72,908/-) made by the learned A.O. under sectio

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.

Create a free accountSign in

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 132

All 14,598 judgments and leading authorities on Section 132 →

Recent GST High Court judgments

Search GST case law →