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TMI Blog2023 (8) TMI 511X X X X Extracts X X X X X X X X Extracts X X X X ..... to the unaccounted jewellery seized or belonging to his family. In the group case of Pallavi Mittal [ 2021 (9) TMI 1335 - ITAT DELHI] considered the similar details filed by father-in-law of assessee [Pallavi Mittal] and observed that the very purpose of centralization of the cases of family members is to have a comprehensive understanding and determination of undisclosed income. Accordingly, in that case the undisclosed income accounted by the father-in-law was taken into account for the jewellery allegedly found in the locker of Pallavi Mittal. The seized component of the assessee has been duly accounted by her husband. Revenue authorities have given the benefit to the assessee of the Circular No. 1916 dated 11.05.1994 at the ti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... order dated 14.12.2016 passed 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 cl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... investment in jewellery. I have carefully 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 Satna ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ial on record it can be observed that learned tax authorities below 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 480 1476055 869425 NIHAR MITTAL URMIL MITTAL Value Seized Released (Joint with other 8 family members) Cash - - - Jewellery - - - Silver - - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 centralization of the cases of family members is to have a comprehensive understanding and determination of undisclosed income. Accordingly, in that case the undisclosed income accounted by the father-in-law Shri S.C. Mittal was taken into account for the jewellery allegedly found in the locker of Pallavi Mittal. 9. In the case in hand the aforesaid tabulation establishes that in Rs. 35 lakhs, offered income, Shri Sat Narain Mittal had shown jewellery component of Rs. 22,13,568/-, which is arrived by adding the seized jewelle ..... X X X X Extracts X X X X X X X X Extracts X X X X
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