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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

Sri. D. K Shivakumar, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru

ITA 1064/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Feb 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan Kassessment Year : 2018-19

For Appellant: S/ShriFor Respondent: Shri.Y. V. Raviraj, Sr. Standing Counsel
Section 132(4)Section 143(2)Section 250Section 292CSection 69ASection 69B

Unexplained money based on material seized from residence of the Assessee Rs. 4,50,00,000/- (14) Unexplained jewellery based on material seized from residence of the Assessee Rs. 1,85,00,000/- (15) Capital gain on transaction with M/s. Davanam Constructions Private Limited Rs. 103,36,94,904/- (Substantive ... Assessee Rs. 6,51,53,000/- 13. Unexplained money based on material seized from residence of the Assessee Rs. 4,50,00,000/- 14. Unexplained jewellery based on material seized from residence of the Assessee Rs. 1,85,00,000/- Item No.7 - Unexplained money based on material seized from residence

Geeta Subhash Dalal L/H of Late Subhash B. Dalal, Vadodara vs. The Dy.CIT, Cent. Circle-2, Vadodara

In the result, the appeal of the assessee is allowed

ITA 2173/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad20 Feb 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Jigar Adhyaru, CAFor Respondent: Shri Ravindra, Sr. DR
Section 69A

Appeals) for the sake of brevity] has grossly erred in confirming the addition of Rs. 6,16,620/- u/s. 69A of the Act, being unexplained jewellery without considering the merits of the case and prays your honour to kindly delete the same. 2. On the facts and in the circumstances ... Dalal) vs. DCIT Asst.Year –2018-19 - 3– that the gold jewellery belonged to Smt. Geeta Dalal. Accordingly, the Assessing Officer made an addition of unexplained jewellery amounting to Rs. 6,16,620/- as unexplained income of the assessee under Section 69A of the Act. 4. In appeal

Assistant Commissioner of Income Tax, Central Circle-3(4), Hyderabad vs. Azaj Farooqi, Secunderabad

In the result, appeal filed by the Revenue is dismissed

ITA 63/HYD/2021[2018-19]Status: DisposedITAT Hyderabad18 Feb 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri K.Narsimha Charyआ.अपी.सं /Ita No.63/Hyd/2021 (निर्धारण वर्ा/Assessment Year: 2018-19) Asst.Commissioner Of Vs. Azaj Farooqi Income Tax Hyderabad Central Circle-3(4) [Pan :Aafpf5292G] Hyderabad

For Appellant: Shri P.Murali Mohan Rao,ARFor Respondent: Shri Srinath Sadanala, DR
Section 132Section 69A

Ld.Sr.AR, further submitted that the Ld.CIT(A) erred in deleting the addition of Rs.1,14,91,700/- made u/s 69A of the Act towards unexplained jewellery, without considering the fact that the assessee failed to submit the evidence like wealth tax returns and purchase bills of jewellery etc. The Ld.Sr.AR

Azaj Farooqi, Secunderabad vs. Deputy Commissioner of Income Tax, Central Cirtcle -3(4), Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 110/HYD/2021[2018-19]Status: DisposedITAT Hyderabad18 Feb 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri K.Narsimha Charyआ.अपी.सं /Ita No.63/Hyd/2021 (निर्धारण वर्ा/Assessment Year: 2018-19) Asst.Commissioner Of Vs. Azaj Farooqi Income Tax Hyderabad Central Circle-3(4) [Pan :Aafpf5292G] Hyderabad

For Appellant: Shri P.Murali Mohan Rao,ARFor Respondent: Shri Srinath Sadanala, DR
Section 132Section 69A

Ld.Sr.AR, further submitted that the Ld.CIT(A) erred in deleting the addition of Rs.1,14,91,700/- made u/s 69A of the Act towards unexplained jewellery, without considering the fact that the assessee failed to submit the evidence like wealth tax returns and purchase bills of jewellery etc. The Ld.Sr.AR

Deputy Commissioner of Income Tax, Central Circle-2(3), Queens Road, Bengaluru vs. Shri Kempareddy Govindraju, Domlur, Bengaluru

In the result the appeals of the assessee in ITA No’s 1022 to

ITA 1290/BANG/2024[2014-15]Status: DisposedITAT Bangalore31 Jan 2025AY 2014-15

Bench: Shri Laxmi Prasad Sahu

For Appellant: ITA Nos.1021 to 1024/Bang/2024
Section 131(1)Section 132Section 132(1)Section 143(3)Section 153ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI SOUNDARAJAN K

Shri. Kempareddy Govindraj, Bengaluru vs. Assistant Commissioner of Income Tax, Central Circle-2(3), Bengaluru

In the result the appeals of the assessee in ITA No’s 1022 to

ITA 1024/BANG/2024[2016-17]Status: DisposedITAT Bangalore31 Jan 2025AY 2016-17

Bench: Shri Laxmi Prasad Sahu

For Appellant: ITA Nos.1021 to 1024/Bang/2024
Section 131(1)Section 132Section 132(1)Section 143(3)Section 153ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI SOUNDARAJAN K

Shri. Kempareddy Govindraj, Bengaluru vs. Assistant Commissioner of Income Tax, Central Circle-2(3), Bengaluru

In the result the appeals of the assessee in ITA No’s 1022 to

ITA 1021/BANG/2024[2013-14]Status: DisposedITAT Bangalore31 Jan 2025AY 2013-14

Bench: Shri Laxmi Prasad Sahu

For Appellant: ITA Nos.1021 to 1024/Bang/2024
Section 131(1)Section 132Section 132(1)Section 143(3)Section 153ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI SOUNDARAJAN K

Smt. Dayawanti, New Delhi vs. DCIT, New Delhi

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

ITA 1639/DEL/2010[2006-07]Status: DisposedITAT Delhi31 Jan 2025AY 2006-07

Bench: Shri Yogesh Kumar Us & Shri Manish Agarwal[Assessment Year : 2012-13] Smt. Sangeeta Sawhney, Vs Acit, 6, Link Road, Jangpura Central Circle-7, Extension, New Delhi-110024 New Delhi Pan-Abjps6408A Appellant Respondent [Assessment Year : 2012-13] Smt. Sangeeta Sawhney, Vs Dcit, 6, Link Road, Jangpura Central Circle-7, Extension, New Delhi-110024 New Delhi Pan-Abjps6408A Appellant Respondent Appellant By Dr. Rakesh Gupta, Adv., Shri Somil Aggarwal, Adv. & Shri Deepesh Garg, Adv. Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 28.05.2025 Date Of Pronouncement 18.06.2025 Order Per Manish Agarwal, Am : The Captioned Appeals Have Been Filed By The Assessee Against The Order Dated 29.12.2016 & 30.12.2016 Passed By Ld. Commissioner Of Income Tax (A)-25, Delhi [“Ld.Cit(A)”] In Appeal No.14/15-16/21/16-17 & Appeal No.278/15-16/28/16-17 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Penalty Order Dated 21.09.2015 Passed U/S 271(1)(C) R.W.S 274 Of The Act Pertaining To Assessment Year 2012-13 Respectively.

Section 250Section 271(1)(c)

where the AO after reducing the claim of the assessee of VDIS declaration of 1088.65 grams held the balance jewellery of 2863.25 grams as unexplained jewellery. Since the total jewellery found at 3619.170 gram as evident from the Annexure J-1 & J-2 prepared during the course of search which

Ratika Kumbhat, Jaipur vs. Income Tax Officer, Jaipur

ITA 1017/JPR/2024[2015-16]Status: DisposedITAT Jaipur09 Jan 2025AY 2015-16

Bench: Or At The Time Of Hearing Of Appeal.”

For Appellant: Shri Anil Goyal, CAFor Respondent: Sh. Gautam Singh Choudhary, JCIT-Sr. DR
Section 143(3)Section 250Section 69A

declaration made by assesse under IDS Scheme, 2016. 3. Sec. 69A is applicable only in respect of assets like Unexplained Money, Unexplained Investments, Unexplained Jewellery etc and not on Sundry Debtors It is submitted that Old debtors and current years interest income cannot be added in the income ... judgments given below selected on random basis, show that Sec. 69A is applicable only on the assets like Unexplained Money, Unexplained Immovable Property, and Unexplained Jewellery. Sundry Debtors is not an asset referred to in Sec. 69A. Therefore there is no such thing like Unexplained Sundry Debtors. [2024] 166 taxmann.com

Ajay Data, Alwar vs. Asstt. Commissioner of Income - Tax, Central, Alwar

In the result, appeal of the assessee is allowed

ITA 1183/JPR/2024[2016-17]Status: DisposedITAT Jaipur07 Jan 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri P.C. Parwal (CA)For Respondent: Shri Arvind Kumar, CIT
Section 250Section 69A

already explained in the table in the assessment order on page no. 18. (2.8) total jewellery found 3861.800 grams, jewellery explained 3500.455 grams, unexplained jewellery 361.345 grams (3861.345- 3500.455) (page 24 of assessment order), balance unexplained jewellery 171.07 grams of Ritika (supported by purchase bills) and 190.275 grams of Nidhi ... which were examined and placed on record. During the assessment proceedings, the assessee was asked to explain and furnish documentary evidences regarding Unexplained Cash, Unexplained Jewellery found and seized during the course of search. The submission made by the assessee was examined in detail along with the details furnished. After

Inder Kumar Vaswani, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 998/JPR/2024[2018-19]Status: DisposedITAT Jaipur01 Jan 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri R.K. Bhatra, C.AFor Respondent: Smt. Anita Rinesh, JCIT-DR
Section 127Section 143(2)

During the assessment proceedings also the appellant could not explain part of the jewellery which has been added in the assessment order as the unexplained jewellery. The entire jewellery belongs to the appellant only it is not the case that some of the jewellery belongs to or was purchased ... jewellery for appellant himself only and not allowed the credit of jewellery for his wife Smt. Amita Vaswani out of total alleged unexplained jewellery of 323.49 gms. Accordingly, remaining jewellery weighing 223.49 gms equivalent to Rs.6,65,027/- is upheld by Ld. CIT(A). The present appeal is against

Deputy Commissioner of Income-Tax, Central Circle-1, Mangaluru vs. Sri. Suresh S Kanaji, Bengaluru

In the result, appeal of the revenue is hereby dismissed

ITA 483/BANG/2023[2018-19]Status: DisposedITAT Bangalore18 Dec 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri H Shiva Prasad Reddy, IRSFor Respondent: Shri Sridhar E, CIT (DR)
Section 143(1)Section 153CSection 195

jewellery belonged to her and that there was no jewellery belonging to any other person kept in the premises based on which unexplained jewellery was seized? vii) For the above grounds and any additional grounds that may be agitated during the course of hearing.” 25. The first issue raised ... Revenue is hereby dismissed. 32. The next issue raised by the Revenue pertains to the deletion of an addition made on account of unexplained jewellery by the learned CIT(A). 33. The facts of the case are that during the search proceedings conducted at the residence of the assessee, gold

Narain Singh Yadav Lh Late Smt Bhanvati, Delhi vs. DCIT, Central Circle 15, New Delhi

In the result, the appeal of the assessee is allowed

ITA 124/DEL/2023[2017-18]Status: DisposedITAT Delhi11 Dec 2024AY 2017-18

Bench: Ms. Madhumita Roy & Smt Renu Jauhriassessment Year: 2017-18

For Respondent: Ms. Baljeet Kaur, CIT DR
Section 132Section 142(1)Section 143(3)Section 260Section 271(1)(c)

grounds have been taken by the assessee out of which the sole substantive issue pertains to the addition made on account of unexplained jewellery. Before us, the Ld. AR of the assessee has submitted a paper book containing assessee’s submission filed during the course of assessment proceedings along with

Mamta Jindal, New Delhi vs. ACIT, Cental Circle- 25, New Delhi

In the result, all the appeals are filed by the assessee are dismissed

ITA 427/DEL/2019[2014-15]Status: DisposedITAT Delhi11 Dec 2024AY 2014-15

Bench: Ms. Madhumita Roy & Ms. Renu Jauhriita Nos.425 To 428/D/2019 (Assessment Years: 2011-12, 2012-13 2014-15&2016-17) Mamta Jindal Vs. Acit F-3/12, Model Town, Central Circle – 25 New Delhi -110009 New Delhi "थायीलेखासं./जीआइआरसं/Pan/Gir No: Pan No.Aeepj6955K Appellant .. Respondent

For Appellant: NoneFor Respondent: Sh. Baljeet Kaur, CIT DR
Section 127Section 132Section 132(4)Section 153ASection 69Section 69A

since the transfer orders under Section 127 of the Act dated 19.07.2016 is not in accordance with law. 3. On merit addition treating the unexplained jewellery under Section 69 of the Act is challenge before us. 4. Addition under Section 69A of the Act on the payment made ... This ground will also apply mutatis mutandis to the other appeals wherever raised. Ground No.3 8. The ground in respect of addition on unexplained jewellery under Section 69 of the Act to the tune of Rs.46,45,491/-as raised by the assessee for A.Y. 2016-17 has duly been

Mamta Jindal, New Delhi vs. ACIT, Cental Circle- 25, New Delhi

In the result, all the appeals are filed by the assessee are dismissed

ITA 426/DEL/2019[2012-13]Status: DisposedITAT Delhi11 Dec 2024AY 2012-13

Bench: Ms. Madhumita Roy & Ms. Renu Jauhriita Nos.425 To 428/D/2019 (Assessment Years: 2011-12, 2012-13 2014-15&2016-17) Mamta Jindal Vs. Acit F-3/12, Model Town, Central Circle – 25 New Delhi -110009 New Delhi "थायीलेखासं./जीआइआरसं/Pan/Gir No: Pan No.Aeepj6955K Appellant .. Respondent

For Appellant: NoneFor Respondent: Sh. Baljeet Kaur, CIT DR
Section 127Section 132Section 132(4)Section 153ASection 69Section 69A

since the transfer orders under Section 127 of the Act dated 19.07.2016 is not in accordance with law. 3. On merit addition treating the unexplained jewellery under Section 69 of the Act is challenge before us. 4. Addition under Section 69A of the Act on the payment made ... This ground will also apply mutatis mutandis to the other appeals wherever raised. Ground No.3 8. The ground in respect of addition on unexplained jewellery under Section 69 of the Act to the tune of Rs.46,45,491/-as raised by the assessee for A.Y. 2016-17 has duly been

Mamta Jindal, New Delhi vs. ACIT, Cental Circle- 25, New Delhi

In the result, all the appeals are filed by the assessee are dismissed

ITA 425/DEL/2019[2011-12]Status: DisposedITAT Delhi11 Dec 2024AY 2011-12

Bench: Ms. Madhumita Roy & Ms. Renu Jauhriita Nos.425 To 428/D/2019 (Assessment Years: 2011-12, 2012-13 2014-15&2016-17) Mamta Jindal Vs. Acit F-3/12, Model Town, Central Circle – 25 New Delhi -110009 New Delhi "थायीलेखासं./जीआइआरसं/Pan/Gir No: Pan No.Aeepj6955K Appellant .. Respondent

For Appellant: NoneFor Respondent: Sh. Baljeet Kaur, CIT DR
Section 127Section 132Section 132(4)Section 153ASection 69Section 69A

since the transfer orders under Section 127 of the Act dated 19.07.2016 is not in accordance with law. 3. On merit addition treating the unexplained jewellery under Section 69 of the Act is challenge before us. 4. Addition under Section 69A of the Act on the payment made ... This ground will also apply mutatis mutandis to the other appeals wherever raised. Ground No.3 8. The ground in respect of addition on unexplained jewellery under Section 69 of the Act to the tune of Rs.46,45,491/-as raised by the assessee for A.Y. 2016-17 has duly been

DCIT, Central Circle, Ghaziabad vs. Subhash Tyagi Prop. M/S Krishana Construction, Meerut

In the result, the appeal of the Revenue is dismissed

ITA 1343/DEL/2021[2017-18]Status: DisposedITAT Delhi09 Dec 2024AY 2017-18

Bench: Shri Pradip Kumar Kedia & Shri Sudhir Kumarassessment Year 2017-18

For Respondent: Sh.Sandeep Sapra, Adv
Section 132Section 139(1)Section 143(3)Section 69A

Rs.46,95,682/- and diamond stone for the total value of Rs.21,20,840/- as on 11.08.2016, i.e., date of search as unexplained jewellery / bullion under Section 69A of the Act. 3.1 The AO further observed that in the course of search / survey operation conducted under Section 132/132A ... evidences furnished and found merit in the plea of the assessee on both counts. The relevant paragraphs dealing with additions on account of unexplained jewellery are reproduced hereunder: “8.3 The undersigned has gone through written submission of the assessee and the findings of the AO in the assessment order against

Veenadevi Ajaypat Singhania, Mumbai vs. DCIT-CC-44, Mumbai

In the result, the appeal filed by Smt Ujjwala Singhania is treated as

ITA 4753/MUM/2023[2012-13]Status: DisposedITAT Mumbai26 Nov 2024AY 2012-13

Bench: Shri Br Baskaran () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Pratik JainFor Respondent: Mr. Umesh Sinha, Sr. DR
Section 132

shall first take up the appeal filed by Smt Ujjwala Singhania, wherein the addition of Rs.2,96,044/- relating to unexplained jewellery and the addition of Rs.13,00,000/- relating to unexplained cash are being disputed. 4. The first issue relates to the addition of Rs.2,96,044/- relating unexplained

Ujjwala Akshaypat Singhania, Mumbai vs. DCIT-CC-44, Mumbai

In the result, the appeal filed by Smt Ujjwala Singhania is treated as partly allowed and the appeal filed by Smt Veenadevi Singhania is treated as allowed

ITA 4752/MUM/2023[2012-13]Status: DisposedITAT Mumbai26 Nov 2024AY 2012-13

Bench: Shri Br Baskaran () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Veenadevi Ajaypat Singhania, Dcit-Cc-44, New Hind House, 3 N M Marg, Aayakar Bhavan, Mumbai-400 001. Vs. Mumbai. Pan No. Aanps 7809 Q Appellant Respondent Assessment Year: 2012-13 Ujjwala Akshaypat Singhania, Dcit-Cc-44, New Hind House, 3 Nm Marg, Aayakar Bhavan, Mumbai-400 001. Vs. Mumbai. Pan No. Aapps 3867 G Appellant Respondent

For Appellant: Mr. Pratik JainFor Respondent: Mr. Umesh Sinha, Sr. DR
Section 132

shall first take up the appeal filed by Smt Ujjwala Singhania, wherein the addition of Rs.2,96,044/- relating to unexplained jewellery and the addition of Rs.13,00,000/- relating to unexplained cash are being disputed. 4. The first issue relates to the addition of Rs.2,96,044/- relating unexplained

Deputy Commissioner of Income Tax, Chennai vs. Rangaswamy Bhaskaran, Kodungaiyur

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

ITA 1353/CHNY/2024[2018-19]Status: DisposedITAT Chennai08 Nov 2024AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.D. Anand, AdvocateFor Respondent: Mr.Nilay Baran Som, CIT
Section 132

Ground No. 3 raised by the Revenue is against the addition made ed by the Revenue is against the addition made on account of unexplained jewellery of Rs.1,98,79,000/ on account of unexplained jewellery of Rs.1,98,79,000/- -. The facts as noted are that, during the course ... assessee AO however did not agree with the explanation put forth by the assessee and added the impugned sum by way of unexplained jewellery u/s 69A of and added the impugned sum by way of unexplained jewellery u/s 69A of and added the impugned sum by way of unexplained jewellery