Nirmal Puri Vs ACIT (Delhi High Court)
The Delhi High Court considered an appeal under Section 260A of the Income Tax Act challenging the concurrent findings of the Assessing Officer, the Commissioner of Income Tax (Appeals), and the Income Tax Appellate Tribunal treating 426 grams of gold bullion as unexplained. The appellant, a 70-year-old lady, contended that she lived in a joint family and had received gold ornaments and jewellery from her parents, in-laws, husband, son and other family members. It was submitted that the total gold found in the locker was 1,242 grams, comprising ornaments belonging to the appellant and her daughter-in-law, and therefore could not be regarded as excessive. It was further argued that despite this explanation, the Assessing Officer, by order dated 29.03.2022, treated 426 grams of gold as unexplained, and the addition was subsequently affirmed by the Commissioner of Income Tax (Appeals) on 16.07.2025 and by the Income Tax Appellate Tribunal on 23.12.2025.
The Revenue submitted that all the authorities had concurrently held against the appellant and emphasised that the disputed asset consisted of four 24-carat gold bars rather than gold jewellery. It was pointed out that the authorities had accepted the explanation regarding the gold ornaments and had made no addition in respect of those ornaments, whereas only the gold bars were treated as unexplained.
