DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR vs. SANJAY DHANRAJ JAIN, NAGPUR

Date of Hearing – 18/12/2024 Date of Order – 21/01/2025

O R D E R PER K.M. ROY, A.M.

Aforesaid appeal by the Revenue is against the impugned order dated 18/02/2022, passed by the learned Commissioner of Income Tax (Appeals)–3, Nagpur, [“learned CIT(A)”], for the assessment year 2017–18.

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1. On the facts and circumstances of the case and in law, the ld. CIT(A) erred in deleting the addition of Rs. 75,00,000/- u/s 69A6/- of the IT Act on account of unexplained cash & gold jewellery in spite of fact that there was no supporting evidences to show that 1500 grams was inherited by the assessee.

2. On the facts and circumstances of the case & in law, the Ld. CIT(A) erred in holding that assessee had purchased jewellery worth Rs. 76.72 Lakhs during the period from November 2009 to April 2016 in spite of the facts that the assessee had produced only few purchase bills in cash and the assessee was not filing any Wealth Tax Returns.

3. On the facts and circumstances of the case & in law, the Ld. CIT(A) erred in deleting the addition of Rs. 75,00,000/- u/s 69A of the IT Act on account of 2 Shri Sanjay Dhanraj Jain unexplained cash & gold jewellery in spite of fact that the assessee had disclosed Rs. 1,50,00,000/- during the search on account of unexplained cash & jewellery but offered only Rs. 75,00,000/- in the return of income without any valid reason. 4. The appellant craves leave to add, amend, vary and/or alter any of the above grounds, as and when deemed necessary.”