TaxTMI 
TaxTMI 
2023 (8) TMI 511
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....assed u/s 144 r.w.s 153A(1)(b) of the Income Tax Act, 1961 (hereinafter referred as 'the Act') by the DCIT, Central Circle, Karnal (hereinafter referred as the Ld. AO). 2. The facts in brief are that consequent to search and seizure operation at the residential as well as business premises of M/s. Vishnu Overseas P. Ltd. and Shri Vishnu Eatables India Ltd. Group of cases & bank locker of the assessee on 17.01.2014 and subsequent dates. Assessment proceedings for initiated u/s 153A notice u/s 142(1) along with questionnaires dated 01.07.2015 was issued the ld. AO was primarily examining the issue of jewellery worth Rs. 36,81,549/- as found from the locker of assessee with Punjab National Bank. In this regard the claim of assessee was that t....
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....arefully gone through the submission of the AR and the contentions of the Assessing Officer. I have also perused the assessment order framed in case of Shri Satnarain Mittal, appellant's husband. It is seen that total jewellery found in the possession of Shri Satnarain Mittal, was of Rs. 6,51,510/-. This amount being, undisclosed investment in jewellery was added in the hands of Shri Satnarain Mittal. Therefore, the submission of the AR, in the present appeal that the jewellery found from the Locker No. 14 is explained in the hands of appellant's husband is not correct. This investment of Rs.36,81,549/- in jewellery, is also not covered by undisclosed income declared by appellant's husband Shri Satnarain Mittal. A perusal of the computati....
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....low have given a specific finding that the disputed jewellery recovered from the locker of assessee was not part of the income declared by Shri Sat Narain Mittal, husband of the assessee. In this context it can be appreciated that admitted fact is that jewellery worthy Rs. 36,81,549/- was unearthed by the Department of which Rs. 7,37,513/- was seized by the Department. Learned AO, however, had made addition of whole of the jewellery considering the same to be unexplained asset. Learned AR has placed on record the computation of total income of Shri Sat Narain Mittal, husband of the assessee, for A.Y. 2014-15, wherein undisclosed speculative profit from rice of Rs. 35 lakhs has been mentioned. Learned CIT(Appeals) in para 2.2 of his order ob....
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....sp; 6711839 2213568 4498271 Misc. Income Declared in AY 2014-15 Jewellery 2213568 Cash 1286432 3500000 Jewellery declared income of person wise Urmil Mittal 737513 Nihar Mittal 1476055 7.1 Now from above it can be seen that Shri Sat Narain Mittal, husband of the assessee, staying under the same roof with the assessee ha disclosed an amount equal to the unaccounted jewellery seized or belonging to his family. 8. In the group case of Pallavi Mittal Vs. DCIT (ITA No. 1794/Del/2018 for A.Y. 2014-15) vide order dated 21.09.2021, the Coordinate Bench considered the similar details filed by Shri S.C. Mittal, the father-in-law of Pallavi Mittal and observed that the very purpose of centr....