SANTOSH BANSAL,PATNA vs. JCIT,CENTRAL CIRCLE-16, NEW DELHI

ITA 2168/DEL/2025Status: DisposedITAT Delhi30 January 2026AY 2022-23Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S.RIFAUR RAHMAN (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal noted that the assessee had disclosed jewellery in her income tax returns prior to the search. While the opening balance of jewellery as of 01.04.2006 could not be fully substantiated with proper bills/vouchers, the assessee is a high net worth individual. Therefore, the Tribunal directed the AO to restrict the undisclosed jewellery to 20% of the value of jewellery valued as on 31.03.2022, which amounts to Rs. 1,46,05,349/-.

What were the facts?

A search and seizure operation was conducted on the assessee's premises, during which jewellery and bullion worth Rs. 1,56,76,253/- and Rs. 1,09,55,201/- respectively were found. The assessee was asked to reconcile the jewellery found with her books of account. The assessee provided ledger accounts showing purchases from 2014 to 2019, but the opening balance of jewellery as of 01.04.2006 could not be fully substantiated.

What were the issues?

Whether the opening balance of jewellery as on 01.04.2006, which could not be fully substantiated by documentary evidence, can be treated as undisclosed income, and if so, to what extent.

Which sections of the Income-tax Act were involved?

Section 132,Section 143(2),Section 142(1),Section 34,Section 69B,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCHES ‘A’: NEW DELHI.

For Appellant: Shri Neeraj Jain, CA, Shri P.K. Mishra, CA
For Respondent: Shri Jitender Singh, CIT DR
Hearing: 20.11.2025

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1.

The assessee has filed appeal against the order of the Learned Commissioner of Income Tax (Appeals)-20, New Delhi [“Ld. CIT (A)”, for short] dated 27.02.2025 for the Assessment Year 2022-23. 2

2.

Brief facts of the case are, a search and seizure operation under section 132 of the Income-tax Act, 1961 (for short ‘the Act’) was conducted on 17.11.2021 and on subsequent dates on different business and residential premises of Pacific Group of cases. The case of the assessee was also covered during the search and seizure operation. The assessee filed the original return of income on 29.07.2022 declaring income of Rs.1,42,29,940/-. Su

The order continues below.

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