PCIT v. Nirmal Kumar Minda (2024) 297 Taxman 200 (Delhi)(HC)

S. 69 : Unexplained investments-Search and seizure-Jewellery-Painting-Wrist watches-Considering the income shown by the assessee and family-Tribunal deleted the addition-High Court affirmed the order of the Tribunal.[S. 132, 260A]

Dismissing the appeal of the Revenue the Court held that the jewellery declared/disclosed by joint family of assessee as one unit in its wealth tax return was more than jewellery found during search and the assessee had placed before Assessing Officer item-wise reconciliation of articles mentioned in wealth tax return and Assessing Officer was unable to flag any defect in reconciliation statement submitted by assessee. As regards the paintings the assessee had placed on record valuation report of paintings. Even though two valuers appointed by revenue had estimated worth of paintings differently but revenue had not pointed out any defect in valuation report submitted by expert appointed by assessee. Source of one painting purchased by assessee in 2017 was shown as bank and remaining paintings were claimed by assessee as having been purchased by drawings. As regards investment in wrist watches were purchased from declared income. Order of Tribunal deleting the addition is affirmed. (AY. 2018-19)