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“unexplained jewellery”

Cash Credits & Unexplained ItemsSection 69ASection 69A324 judgments

The decision most relied on for unexplained jewellery is Ashok Chaddha v. ITO (337 ITR 399), cited in 252 judgments on BharatTax.

Leading authorities on unexplained jewellery

Ashok Chaddha v. ITO
337 ITR 399 · 2011 · High Court
252
citing judgments

In search assessments under section 153A, a notice under section 143(2) is not required if a notice under section 153A(1)(a) has been issued. Modest or customary jewellery, commensurate with age and status, found during a search, especially if it is 'Stridhan' or falls within CBDT guidelines, cannot be added as unexplained income.

CIT v. Ratanlal Vyaparilal Jain
339 ITR 351 · 2011 · High Court
113
citing judgments

Jewellery found within the CBDT prescribed limits (500g for married women, 250g for unmarried women, 100g for men) cannot be seized, even if not fully explained. However, its value can be added as undisclosed income under Section 69B if the taxpayer fails to prove its source.

Smt. Neena Syal v. ACIT
70 ITD 62 · 1999 · ITAT
39
citing judgments

Disallowance of expenses cannot be made if their genuineness is not challenged. For unexplained money, possession of gold jewellery by married ladies up to 500 grams is considered explained.

Chadha v. ITO
202 Taxmann 395 · 2011 · High Court
37
citing judgments

Jewellery found during a search that is adequately explained as being owned by a married lady for a long time, even without documentary evidence, should not be added to income, as this recognizes realities of life.

CIT v. Satya Narain Patni
46 Taxmann.com 440 · 2014 · High Court
33
citing judgments

Jewellery found in possession, to the extent permitted by Instruction No. 1916 (which exempts up to 100 gms of gold for unmarried male members), cannot be treated as an undisclosed investment.

Revenue. In Asstt.CIT v. Ramesh Chandra R. Patel
89 ITD 203 · 2004 · ITAT
32
citing judgments

Jewellery within prescribed limits, especially that received during marriage, is presumed explained even if found during a search, based on CBDT instructions. The revenue cannot treat such jewellery as unexplained income simply because it was found.

Pati Devi v. ITO
240 ITR 727 · 1999 · High Court
27
citing judgments

Jewellery up to prescribed limits (e.g., 500 grams for a married lady, 100 grams for a male member, as per CBDT Instruction No. 1916) is presumed to be explained. The revenue must rebut this presumption to treat such jewellery as unexplained.

449 (Madras), Sterling Machine Tools v. CIT
122 ITR 926 · High Court
22
citing judgments

Unexplained jewellery found during a search can be added to income, even if the assessee claims it was received back against purchase bills, especially when part of the unaccounted cash is deposited in the bank.

Judgments citing unexplained jewellery

ACIT-Circle-2(1)(1), Agra vs. Puneet Agarwal, Agra

In the result, the appeal filed by the assessee is allowed, the CO raised by the assessee and appeal filed by the Revenue are dismissed

ITA 338/AGR/2025[2015-16]Status: DisposedITAT Agra04 Dec 2025AY 2015-16

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 132(1)Section 132(4)

discussed each and every issue from pages 58 onwards and observed as under:- a). Regarding the unexplained jewellery of Rs.99,31,727/-, for which, the addition have been made in the hands of Shri V.D.Agarwal on substantive basis, it observed by the Ld. CIT(A) that jewellery belongs ... basis of the some ‘dumb document’, which was further retracted. 2. Substantive Addition on account of alleged 99,31,727/- Page 17 to 18 Unexplained Jewellery. ( Protective addition made in the hands of his two sons namely, Sh. Mayank Agarwal and Sh.Puneet Agarwal of the assessee. 3. Addition on account

ACIT, Circle-2(1)(1), Agra vs. Sh. Vishwambhar Dayal Agarwal, Agra

ITA 337/AGR/2025[2015-16]Status: DisposedITAT Agra04 Dec 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 132(1)Section 132(4)

discussed each and every issue from pages 58 onwards and observed as under:- a). Regarding the unexplained jewellery of Rs.99,31,727/-, for which, the addition have been made in the hands of Shri V.D.Agarwal on substantive basis, it observed by the Ld. CIT(A) that jewellery belongs ... during the course of search on the basis of the some ‘dumb document', which was further retracted. 2. Substantive Addition on account of alleged Unexplained Jewellery. ( Protective addition made in the hands of his two sons 99,31,727/- Page 17 to 18 namely, Sh. Mayank Agarwal and Sh.Puneet Agarwal

ACIT-Circel-2(1)(1), Agra vs. Mayank Agrawal, Agra

In the result, the appeal filed by the assessee is allowed, the CO raised by the assessee and appeal filed by the Revenue are dismissed

ITA 336/AGR/2025[2015-16]Status: DisposedITAT Agra04 Dec 2025AY 2015-16

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 132(1)Section 132(4)

discussed each and every issue from pages 58 onwards and observed as under:- a). Regarding the unexplained jewellery of Rs.99,31,727/-, for which, the addition have been made in the hands of Shri V.D.Agarwal on substantive basis, it observed by the Ld. CIT(A) that jewellery belongs ... basis of the some ‘dumb document’, which was further retracted. 2. Substantive Addition on account of alleged 99,31,727/- Page 17 to 18 Unexplained Jewellery. ( Protective addition made in the hands of his two sons namely, Sh. Mayank Agarwal and Sh.Puneet Agarwal of the assessee. 3. Addition on account

Vishwambhar Dayal Agarwal, Agra vs. Deputy Commissioner of Income Tax, Circle2(1)(1), Agra

In the result, the appeal filed by the assessee is allowed, the CO raised by the assessee and appeal filed by the Revenue are dismissed

ITA 330/AGR/2025[2015-16]Status: DisposedITAT Agra04 Dec 2025AY 2015-16

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 132(1)Section 132(4)

discussed each and every issue from pages 58 onwards and observed as under:- a). Regarding the unexplained jewellery of Rs.99,31,727/-, for which, the addition have been made in the hands of Shri V.D.Agarwal on substantive basis, it observed by the Ld. CIT(A) that jewellery belongs ... basis of the some ‘dumb document’, which was further retracted. 2. Substantive Addition on account of alleged 99,31,727/- Page 17 to 18 Unexplained Jewellery. ( Protective addition made in the hands of his two sons namely, Sh. Mayank Agarwal and Sh.Puneet Agarwal of the assessee. 3. Addition on account

Sh. Vivek Gupta, Haryana vs. ACIT/DCIT, Haryana

In the result, the appeal of the assessee is partly allowed

ITA 5037/DEL/2025[2018-19]Status: DisposedITAT Delhi04 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2018-19] Shri Vivek Gupta Vs Acit/Dcit C-5/2A, Opp. C. C. Colony Central Circle Rana Pratap Bagh, North Delhi Karnal Delhi-110007 Pan-Aappg4029A Appellant Respondent Appellant By Shri Ved Jain, Adv. & Ms. Uma Upadhyay, Ca Respondent By Ms. Amisha S.Gupt, Cit Dr Date Of Hearing 04.12.2025 Date Of Pronouncement 04.12.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 29.07.2025 By Ld. Commissioner Of Income Tax (A)-3, Gurgaon [“Ld.Cit(A)”] In Appeal No.10453/2019-20 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 29.12.2019 Passed U/S 143(3) R.W.S. 153B(1)(B) Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That A Search & Seizure Operation U/S 132 Were Carried Out At The Business Premises Of M/S. Oswal Group Of Cases, Karnal & Residential Premises Of Its Members On 22.01.2018. The Case Of The Assessee Was Also Covered U/S 132 Of The Act. Assessee Filed His Return Of Income On 28.07.2018 Declaring Total Income Of Inr 13,36,300/-. Thereafter, Statutory Notice U/S 143(2) Of The Act Was Issued On 23.04.2019 Followed By Notices U/S 142(1) Of The Act Alongwith Questionnaire Issued From Time To Time. In Response To Above, Assessee Filed Replies. Thereafter, The Ao Passed The Assessment Order U/S 143(3) R.W.S. 153B(1)(B) Of The Act Dated 29.12.2019 Assessing Total Income Of The Assessee At Inr 81,59,730/-.

Section 115BSection 132Section 142(1)Section 143(2)Section 143(3)Section 153DSection 250Section 69Section 69A

thus, no addition is required to be made on this score. Ld. AR, therefore, prayed for the deletion of the additions made towards alleged unexplained jewellery. 12. On the other hand, Ld. CIT DR for the Revenue submits that assessee has failed to substantiate the source of the acquisition

Deputy Commissioner of Income Tax Central Circle 27, New Delhi vs. Anand Kumar Chaurasia, Delhi

In the result, the appeal filed by the Revenue is dismissed

ITA 1734/DEL/2024[2020-21]Status: DisposedITAT Delhi26 Nov 2025AY 2020-21

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Amit Jain, CITDR
Section 143(3)Section 153ASection 68Section 69C

sale of 68 82,67,44,250 diamonds 4 Commission expenditure on sale of 69C 14,88,140 diamonds @ 0.18% of sale consideration 5 Unexplained jewellery (Protective - 2,05,13,354 Basis) 3.1 He submitted that against the aforesaid assessment order, the assessee preferred an appeal before ... under section 69C on account of alleged commission expenditure was confirmed; and (ii) Protective addition of Rs.2,05,13,134/- on account of unexplained jewellery was deleted. 3.2 He further submitted that against the aforesaid order passed by the ld. CIT(A), the assessee has preferred appeal on issues mentioned

Sh. Anand Kumar Chaurasia, Delhi vs. Deputy Commissioner of Income Tax, Central Circle-27, New Delhi, Delhi

In the result, the appeal filed by the Revenue is dismissed

ITA 1324/DEL/2024[2020-21]Status: DisposedITAT Delhi26 Nov 2025AY 2020-21

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Amit Jain, CITDR
Section 143(3)Section 153ASection 68Section 69C

sale of 68 82,67,44,250 diamonds 4 Commission expenditure on sale of 69C 14,88,140 diamonds @ 0.18% of sale consideration 5 Unexplained jewellery (Protective - 2,05,13,354 Basis) 3.1 He submitted that against the aforesaid assessment order, the assessee preferred an appeal before ... under section 69C on account of alleged commission expenditure was confirmed; and (ii) Protective addition of Rs.2,05,13,134/- on account of unexplained jewellery was deleted. 3.2 He further submitted that against the aforesaid order passed by the ld. CIT(A), the assessee has preferred appeal on issues mentioned

Anup Kumar Aggarwal, Panchkula vs. ACIT(Central) Shimla, Shimla

Appeal stand allowed in terms of our above order

ITA 1018/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh24 Nov 2025AY 2020-21

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Sh. Ajay Jain (CA)a/w Shri Lovesh BansalFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR
Section 127Section 144BSection 147Section 148Section 151ASection 69A

assessment framed by Ld. AO u/s 147 of the Act on 12-03-2025. The assessee is aggrieved by confirmation of addition of unexplained jewellery u/s 69A for Rs.78,260/-. The additions stem from search action by the department on assessee-group on 04-11-2022. Subsequent to search action

DCIT, Chennai vs. Jagathrakshakan Srinisha, Chennai

ITA 1271/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Nov 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 1253, 1264 & 1271/Chny/2025 निर्धारण वर्ष / Assessment Year: 2017-18 Dcit, Central Circle -2(3), Chennai. (अपीलार्थी/Appellant) Vs. Jagathrakshakan Srinisha, 1St Main Road, Adyar, Besant Nagar, Chennai - 600 020. Tamil Nadu. [Pan: Abfps-1422-E] (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri. B. Ramakrishnan, Fca & Shri. Shrenik Chordia, Ca. राजस्व की ओर से / Revenue By : Shri. C.N. Bipin, C.I.T. सुनवाई की तारीख /Date Of Hearing : 07.11.2025 घोषणा की तारीख/Date Of Pronouncement : 18.11.2025 आदेश /Order Per S.R.Raghunatha, Am: The Present Appeal Is Preferred By The Revenue Against The Order Dated 06.02.2025 Passed By The Commissioner Of Income Tax (Appeals)-19 (Hereinafter Referred To As Ld.Cit(A), Chennai, In Respect Of The Assessment Order Dated 01.03.2019 Passed By The Deputy Commissioner Of Income Tax, Central Circle -2(3) (Hereinafter Referred To As Ao) For The Assessment Year 2017-18 (Hereinafter Referred To As The Impugned Assessment Year) U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As The Act). :-2-:

For Appellant: Shri. B. Ramakrishnan, FCA &For Respondent: Shri. C.N. Bipin, C.I.T
Section 131Section 132Section 143(3)Section 154Section 270A

year wise from AY's 2011-12 to 2016-17 as available in pg no.6 para 3 above, sought to explain part of the unexplained jewellery to an extent of Rs. 4,52,07,120/-. In this regard the following submissions are being made: 1. It is submitted that

DCIT, Chennai vs. Jagathrakshakan Srinisha, Chennai

ITA 1264/CHNY/2025[2017]Status: DisposedITAT Chennai18 Nov 2025

Bench: Shri Aby T Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 1253, 1264 & 1271/Chny/2025 निर्धारण वर्ष / Assessment Year: 2017-18 Dcit, Central Circle -2(3), Chennai. (अपीलार्थी/Appellant) Vs. Jagathrakshakan Srinisha, 1St Main Road, Adyar, Besant Nagar, Chennai - 600 020. Tamil Nadu. [Pan: Abfps-1422-E] (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri. B. Ramakrishnan, Fca & Shri. Shrenik Chordia, Ca. राजस्व की ओर से / Revenue By : Shri. C.N. Bipin, C.I.T. सुनवाई की तारीख /Date Of Hearing : 07.11.2025 घोषणा की तारीख/Date Of Pronouncement : 18.11.2025 आदेश /Order Per S.R.Raghunatha, Am: The Present Appeal Is Preferred By The Revenue Against The Order Dated 06.02.2025 Passed By The Commissioner Of Income Tax (Appeals)-19 (Hereinafter Referred To As Ld.Cit(A), Chennai, In Respect Of The Assessment Order Dated 01.03.2019 Passed By The Deputy Commissioner Of Income Tax, Central Circle -2(3) (Hereinafter Referred To As Ao) For The Assessment Year 2017-18 (Hereinafter Referred To As The Impugned Assessment Year) U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As The Act). :-2-:

For Appellant: Shri. B. Ramakrishnan, FCA &For Respondent: Shri. C.N. Bipin, C.I.T
Section 131Section 132Section 143(3)Section 154Section 270A

year wise from AY's 2011-12 to 2016-17 as available in pg no.6 para 3 above, sought to explain part of the unexplained jewellery to an extent of Rs. 4,52,07,120/-. In this regard the following submissions are being made: 1. It is submitted that

DCIT, Chennai vs. Jagathrakskan Srinisha, Chennai

In the result, the appeals filed by the Revenue in I

ITA 1253/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Nov 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 1253, 1264 & 1271/Chny/2025 निर्धारण वर्ष / Assessment Year: 2017-18 Dcit, Central Circle -2(3), Chennai. (अपीलार्थी/Appellant) Vs. Jagathrakshakan Srinisha, 1St Main Road, Adyar, Besant Nagar, Chennai - 600 020. Tamil Nadu. [Pan: Abfps-1422-E] (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri. B. Ramakrishnan, Fca & Shri. Shrenik Chordia, Ca. राजस्व की ओर से / Revenue By : Shri. C.N. Bipin, C.I.T. सुनवाई की तारीख /Date Of Hearing : 07.11.2025 घोषणा की तारीख/Date Of Pronouncement : 18.11.2025 आदेश /Order Per S.R.Raghunatha, Am: The Present Appeal Is Preferred By The Revenue Against The Order Dated 06.02.2025 Passed By The Commissioner Of Income Tax (Appeals)-19 (Hereinafter Referred To As Ld.Cit(A), Chennai, In Respect Of The Assessment Order Dated 01.03.2019 Passed By The Deputy Commissioner Of Income Tax, Central Circle -2(3) (Hereinafter Referred To As Ao) For The Assessment Year 2017-18 (Hereinafter Referred To As The Impugned Assessment Year) U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As The Act). :-2-:

For Appellant: Shri. B. Ramakrishnan, FCA &For Respondent: Shri. C.N. Bipin, C.I.T
Section 131Section 132Section 143(3)Section 154Section 270A

year wise from AY's 2011-12 to 2016-17 as available in pg no.6 para 3 above, sought to explain part of the unexplained jewellery to an extent of Rs. 4,52,07,120/-. In this regard the following submissions are being made: 1. It is submitted that

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Jagjit Singh Grewal, Ludhiana

In the result, appeal of the assessee is allowed and that

ITA 357/CHANDI/2025[2022-23]Status: DisposedITAT Chandigarh17 Nov 2025AY 2022-23

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1242/Chd/2024 निर्धारण वर्ष / Assessment Year: 2022-23 Shri Jagjit Singh Grewal, Barewal, Awana, Ferozepur Road, Ludhiana. Vs The Dcit, Central Circle-1, Ludhiana. स्थायी लेखा सं./Pan No: Ahjpg1260E अपीलार्थी/Appellant प्रत्यर्थी/Respondent आयकर अपील सं./ Ita No. 357/Chd/2025 The Dcit, Central Circle-1, Ludhiana. निर्धारण वर्ष / Assessment Year: 2022-23 Shri Jagjit Singh Grewal, Barewal, Awana, Ferozepur Road, Ludhiana. V S स्थायी लेखा सं./Pan No: Ahjpg1260E अपीलार्थी/Appellant प्रत्यर्थी/Respondent Assessee By: Shri Sudhir Sehgal, Advocate Revenue By: Shri Manav Bansal, Cit Dr Date Of Hearing : 21.08.2025 Date Of Pronouncement : 17.11.2025 Per Rajpal Yadav, Vp Order The Assessee & Revenue Are In Cross-Appeals Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) [In Short ‘The Cit (A)'] Dated 14.12.2024 Passed For

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR

Revenue has also pleaded that ld.CIT (Appeals) has erred in partially deleting the addition made by the AO on account of unexplained jewellery found during the course of search. 3. The brief facts of the case are that assessee is an individual. He has filed his return of income ... grams out of total jewellery of 4134.07 grams, found at the time of search. The ld.CIT (Appeals) confirmed the addition on account of unexplained jewellery to the extent of 943.91 grams and the value was determined at Rs.46,96,225/-. The addition deleted is being challenged by the Revenue

Jagjit Singh Grewal, Barewal Awana, Ferozepur Road, Ludhiana vs. Deputy Commissioner of Income Tax, CC1, Ludhiana

In the result, appeal of the assessee is allowed and that of the Revenue is dismissed

ITA 1242/CHANDI/2024[2022-2023]Status: DisposedITAT Chandigarh17 Nov 2025AY 2022-2023

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1242/Chd/2024 "नधा"रण वष" / Assessment Year: 2022-23 Shri Jagjit Singh Grewal, The Dcit, Barewal, Awana, Vs Central Circle-1, Ferozepur Road, Ludhiana. Ludhiana. "थायी लेखा सं./Pan No: Ahjpg1260E अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita No. 357/Chd/2025 "नधा"रण वष" / Assessment Year: 2022-23 The Dcit, Shri Jagjit Singh Grewal, Central Circle-1, V Barewal, Awana, Ludhiana. S Ferozepur Road, Ludhiana. "थायी लेखा सं./Pan No: Ahjpg1260E अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR

Revenue has also pleaded that ld.CIT (Appeals) has erred in partially deleting the addition made by the AO on account of unexplained jewellery found during the course of search. 3. The brief facts of the case are that assessee is an individual. He has filed his return of income ... grams out of total jewellery of 4134.07 grams, found at the time of search. The ld.CIT (Appeals) confirmed the addition on account of unexplained jewellery to the extent of 943.91 grams and the value was determined at Rs.46,96,225/-. The addition deleted is being challenged by the Revenue

Sunil Kumar Gattani, Jaipur vs. The Asstt. Commissioner of Income Tax Central Circle - 2, Jaipur

In the result ground no. 7

ITA 1142/JPR/2025[2019-20]Status: DisposedITAT Jaipur13 Nov 2025AY 2019-20
For Appellant: Sh. Tarun Mittal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 115BSection 131Section 132Section 132(4)Section 143(3)Section 69Section 69A

mention the same in his statements due to charged atmosphere during search. So, I find that this explanation of the appellant for the unexplained jewellery is too far stretched and cannot be accepted. Further, though the appellant furnished the valuation report date 16.06.1999 however, no such jewellery declared in this ... such evidence/document has been given by the appellant in support of this claim. So, this justification does not merit consideration for explanation of unexplained jewellery. From the bills produced during course of search proceedings, the jewellery of 875 gms was considered explained and was exempted by search team from seizure

ACIT, C R Building vs. Gurpreet Kochar, K.G.Marg

In the result, Revenue’s appeal ITA No

ITA 3465/DEL/2023[2017-18]Status: DisposedITAT Delhi07 Nov 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year: 2017-18

Section 132Section 143(3)Section 69Section 69A

Ground of Appeal Nos. 2 to 2.5 & 5 to 5.1 relate to addition of Rs. 1,11,15,429/-being the amount of unexplained jewellery out of the jewellery of Rs. 1,24,80,429/- found from the possession of the appellant under section 69 (A) of the Income ... being unexplained jewellery found from the locker no. 983, Punjab and Sind Bank, Malkaganj. New Delhi jointly held by appellant and Mrs. Gurmeet Kaur. 5.1 The main objection of the AO was that the appellant was not able to give one to one reconciliation between the declared jewellery and jewellery

Deputy Commissioner of Income-Tax, Central Circle-4, Surat vs. Vikas Nangalia, Surat

In the result, appeal of revenue and CO of assessee are dismissed

ITA 972/SRT/2024[2020-21]Status: DisposedITAT Surat31 Oct 2025AY 2020-21

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.972/Srt/2024& Assessment Year: 2020-21 (Physical Court Hearing) Deputy Commissioner Of Vikas Nangalia बनाम/ Income-Tax, Central Circle-4, D-1112, Canal Road, Surya Green Vs. Surat Room No.508, Majura View, Vesu, Surat-395 007 Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpn 1361 L (अपीलाथ"/Appellant) (""थ" /Respondent) ""ा"ेप सं /Co No.26/Srt/2024 (A/O Ita No.972/Srt/2024) Assessment Year: 2020-21 Vikas Nangalia Deputy Commissioner Of बनाम/ D-1112, Canal Road, Surya Green Income-Tax, Central Circle-4, Vs. View, Vesu, Surat-395 007 Surat Room No.508, Majura Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpn 1361 L (Co-Objector) (""थ" /Respondent) आयकर अपील सं./Ita No.848/Srt/2024& Assessment Year: 2021-22 Deputy Commissioner Of Vikas Nangalia बनाम/ Income-Tax, Central Circle-4, D-1112, Canal Road, Surya Green Vs. Surat Room No.508, Majura View, Vesu, Surat-395 007 Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpn 1361 L (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Assessee By Shri Ramesh Malpani, Ca राज" की ओर से /Revenue By Shri Mukesh Jain, Cit-Dr सुनवाई की तारीख/Date Of Hearing 08/09/2025 उद्घोषणा की तारीख/Date Of Pronouncement 31/10/2025

Section 143(3)Section 250Section 69ASection 69C

case and in law, the Ld. CIT(A) erred in deleting the addition of Rs.39,53,201/- made by the AO on account of unexplained jewellery despite the fact that the assessee has not been able to explain source of investment in such jewellery during the course of the assessment ... case and in law, the Ld. CIT(A) erred in deleting the addition of Rs.39,53,201/- made by the AO on account of unexplained jewellery and without appreciating his own observation in the order that there stood difference as per VDIS declaration and as found in course

Deputy Commissioner of Income Tax, Central Circle-4, Surat, Aaykar Bhawan, Majura Gate vs. Vikas Nangalia, Vesu Surat, Gujarat

In the result, appeal of revenue and CO of assessee are dismissed

ITA 848/SRT/2024[2021-22]Status: DisposedITAT Surat31 Oct 2025AY 2021-22

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.972/Srt/2024& Assessment Year: 2020-21 (Physical Court Hearing) Deputy Commissioner Of Vikas Nangalia बनाम/ Income-Tax, Central Circle-4, D-1112, Canal Road, Surya Green Vs. Surat Room No.508, Majura View, Vesu, Surat-395 007 Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpn 1361 L (अपीलाथ"/Appellant) (""थ" /Respondent) ""ा"ेप सं /Co No.26/Srt/2024 (A/O Ita No.972/Srt/2024) Assessment Year: 2020-21 Vikas Nangalia Deputy Commissioner Of बनाम/ D-1112, Canal Road, Surya Green Income-Tax, Central Circle-4, Vs. View, Vesu, Surat-395 007 Surat Room No.508, Majura Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpn 1361 L (Co-Objector) (""थ" /Respondent) आयकर अपील सं./Ita No.848/Srt/2024& Assessment Year: 2021-22 Deputy Commissioner Of Vikas Nangalia बनाम/ Income-Tax, Central Circle-4, D-1112, Canal Road, Surya Green Vs. Surat Room No.508, Majura View, Vesu, Surat-395 007 Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpn 1361 L (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Assessee By Shri Ramesh Malpani, Ca राज" की ओर से /Revenue By Shri Mukesh Jain, Cit-Dr सुनवाई की तारीख/Date Of Hearing 08/09/2025 उद्घोषणा की तारीख/Date Of Pronouncement 31/10/2025

Section 143(3)Section 250Section 69ASection 69C

case and in law, the Ld. CIT(A) erred in deleting the addition of Rs.39,53,201/- made by the AO on account of unexplained jewellery despite the fact that the assessee has not been able to explain source of investment in such jewellery during the course of the assessment ... case and in law, the Ld. CIT(A) erred in deleting the addition of Rs.39,53,201/- made by the AO on account of unexplained jewellery and without appreciating his own observation in the order that there stood difference as per VDIS declaration and as found in course

Rajesh Poddar, Surat vs. ACIT Central Circle-4, Surat

In the result, assessee's appeal is dismissed

ITA 547/SRT/2024[2020-21]Status: DisposedITAT Surat31 Oct 2025AY 2020-21
Section 143(3)Section 292CSection 69BSection 69C

granting relief towards gift received by the assessee and his family members without appreciating the facts that the AO has calculated the value of unexplained jewellery on the basis of the WT returns filed by the family members and valid bills provided by the assessee during the course ... added in the hands of the assessee u/s 69B of the Act. The AO also added unexplained jewellery of Rs.3,48,27,683/- u/s 69B of the Act. Aggrieved by the order of AO, assessee filed appeal before CIT(A). 5. The appellant challenged validity of the order passed

ACIT, CC- 15, New Delhi vs. Saloni Narang, New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1496/DEL/2018[2012-13]Status: DisposedITAT Delhi27 Oct 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2012-13] Asst. Commissioner Of Income Saloni Narang, Tax, Central Circle-15, 5, Dr. G.G. Narang Marg, Room No.353, E-2, Ara Vs Cavalary Lane, Centre, Jhandewalan Ext. Delhi-110007 New Delhi-110055 Pan-Aafpn2692C Appellant Respondent Assessee By Dr. Rakesh Gupta, Adv. & Shri Somil Agarwal, Adv. Revenue By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 31.07.2025 Date Of Pronouncement 27.10.2025

Section 132Section 143(3)Section 153Section 153ASection 153DSection 69A

erred in deleting the addition of (Rs.2,01,34,392-Rs.32,75,479) Rs. 1,68,58,913/- made by AO on account of unexplained jewellery seized from the premises of the assessee. 3. At the outset, the ld. Counsel for the assessee invited our attention to its petition dated

ACIT, Central Circle-2(4), Bangalore vs. Ramchandra Naveen, Bangalore

ITA 2083/BANG/2024[2018-19]Status: DisposedITAT Bangalore26 Sept 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. V. Srinivasan, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 132(4)Section 153A

facts and circumstances of the case and in law, the Ld. CIT(A) was right in deleting the addition made on account of unexplained jewellery without considering the fact that the assessee has admitted the same in the statements recorded ... facts and circumstances of the case and in law, the Ld. CIT(A) was right in deleting the addition made on account of unexplained jewellery by placing reliance on CBDT instruction 1916 dated 11.05.1994 without considering the fact that the said instruction is for the purpose of seizure of jewellery