आयकर अपील(cid:547)य अ(cid:876)धकरण,चÖडीगढ़ Ûयायपीठ, चÖडीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘A’ CHANDIGARH BEFORE SHRI RAJPAL YADAV, VICE PRESIDENT AND SHRI MANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No. 1242/CHD/2024 (cid:467)नधा(cid:91)रण वष (cid:91) / Assessment Year: 2022-23 Shri Jagjit Singh Grewal, The DCIT, Barewal, Awana, Vs Central Circle-1, Ferozepur Road, Ludhiana.

Ludhiana.

èथायी लेखा सं./PAN NO: AHJPG1260E अपीलाथ(cid:568)/Appellant (cid:292)×यथ(cid:568)/Respondent आयकर अपील सं./ ITA No. 357/CHD/2025 (cid:467)नधा(cid:91)रण वष(cid:91) / Assessment Year: 2022-23 The DCIT, Shri Jagjit Singh Grewal, Central Circle-1, V Barewal, Awana, Ludhiana. s Ferozepur Road, Ludhiana.

èथायी लेखा सं./PAN NO: AHJPG1260E अपीलाथ(cid:568)/Appellant (cid:292)×यथ(cid:568)/Respondent Assessee by : Shri Sudhir Sehgal, Advocate Revenue by : Shri Manav Bansal, CIT DR Date of Hearing : 21.08.2025 Date of Pronouncement : 17.11.2025 PHYSICAL HEARING O R D E R PER RAJPAL YADAV, VP The assessee and Revenue are in cross-appeals against the order of the ld. Commissioner of Income Tax (Appeals) [in short ‘the CIT (A)’] dated 14.12.2024 passed for assessment year 2022-23. The issues agitated in both the appeals are inter-connected with each other, therefore, we take both the appeals together.

2. The grievance of the assessee is that ld.CIT (Appeals) has erred in partially retaining the addition on account of unexplained investment in jewellery whereas in ground No. 1 and 2, the Revenue has also pleaded that ld.CIT (Appeals) has erred in partially deleting the addition made by the AO on account of unexplained jewellery found during the course of search.

3. The brief facts of the case are that assessee is an individual. He has filed his return of income on 17.10.2022 declaring an income of Rs.75,04,710/-. There was a search in Home Life Buildcon Pvt. Ltd. Group. The assessee is a member of this group and the search was caried out on 16.11.2021. During the course of search, jewellery having weight of 4137.07 grams was found. The value of this jewellery was worked out at Rs.2,06,70,635/-. The Income Tax Department has seized jewellery to the extent of 2443.91 grams. The value of this jewellery was determined at Rs.1,21,59,164/-.During the course of assessment proceedings, assessee has given explanation qua the source of this jewellery but this was rejected by the AO and he made an addition of Rs.1,21,59,164/-.

4. Dissatisfied with the finding of the AO, assessee carried the matter in appeal before the ld.CIT (Appeals). The ld.CIT (Appeals) has partly deleted the addition. According to the finding of the CIT (Appeals), the AO has allowed the benefit of CBDT Circular No. 1916 dated 11.05.1994 to the extent of 1690.16 grams. The AO was of the view that there were two ladies in the family, namely, Smt. Balwinder Kaur, mother of the assessee and Smt. Jaswinder Kaur, wife of the assessee. He has further granted benefit of the jewellery according to the Circular qua two minor daughters of Shri Jagjit Singh. He granted benefit of this Circular qua the limit could be retained by a male member, Shri Jagjit Singh and Shri Samir Singh, son of the assessee. The ld.CIT (Appeals) further observed that there were two more ladies whose jewellery was available in the family, namely, Smt. Jasmine Kaur, wife of Shri Interjeet Singh, brother of the assessee Shri Jagjit Singh and Smt. Jaspreet Kaur, wife of Shri Mandeep Singh, second brother of the assessee. Hence, out of the total seizure, he has granted benefit6 of 3190.16 grams out of total jewellery of 4134.07 grams, found at the time of search. The ld.CIT (Appeals) confirmed the addition on account of unexplained jewellery to the extent of 943.91 grams and the value was determined at Rs.46,96,225/-. The addition deleted is being challenged by the Revenue in its appeal and the addition retained above is being challenged by the assessee in its cross-appeals.

5. With the assistance of the ld. R