The ITAT, on appeal, held that the assessee explained that she held sufficient opening cash balance as on 1.04.2016 amounting to Rs. 7,46,464 and apart from that the assessee disclosed income of Rs. 7,28,080. The assessee’s sources were to the tune of Rs. 14.70 lakhs, if the cash-in-hand of Rs. 7,46,464 was included, apart from current year’s income. Hence, the assessee could explain the source of purchase of agricultural land at Rs. 7.50 lakhs. The balance Rs. 2.61 lakhs remained unexplained and was added.

Lastly, in respect of the disputed gold jewellery of 316 gms. seized, the CIT(A) had not taken into consideration that 75 sovereigns were received by the assessee from her parents. Hence, the gold jewellery of 316 gms. was explained and the addition therefore, was deleted. (AY.2016-17, 2017-18, 2018-19)