Asha Ranjit Shivdasani v/s. Assistant Commissioner of Income Tax (Appeals)
Case No: ITA No.2312/MUM/2025 (A.Y. 2019-20)
Court: INCOME-TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI
Date: 1/19/2026
Parties Involved
appellantAsha Ranjit Shivdasani
respondentAssistant Commissioner of Income Tax (Appeals)
Facts Summary
The assessee, Asha Ranjit Shivdasani, filed her original return of income declaring a total income of Rs. 43,85,500/-. A search and seizure operation under section 132(1) of the Income-tax Act was conducted on 30/10/2018 at her residence and in locker no. 443 maintained with State Bank of India, Napean Sea Road Branch. During the search, gold and diamond jewellery were found, valued at Rs. 71,44,441 at her residence and Rs. 22,71,080 in the locker. The assessee admitted ownership of the jeweller…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the Learned Commissioner of Income-tax, Appeal (CIT(A)) erred in confirming the addition made by the Assessing Officer (AO) under section 69A of the Income-tax Act without recording any specific finding on the source of funds of the jewellery identified during the search proceedings.
- 2. Whether the CIT(A) erred in disregarding the facts of the case and confirming the assessment order under section 143(3) of the Income-tax Act, wherein addition under section 69A was made by treating jewellery received by the appellant as per Hindu rituals as unexplained.
Precedents Relied Upon
2 precedents cited in this judgement.