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IN THE INCOME TAX APPELLATE TRIBUNAL

“F” BENCH MUMBAI

BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER &

SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER

ITA No. 5265/Mum/2025

(Assessment Year: 2020-21)

Jigna Kundan Bhatt DCIT Cen. Cir. 1(1),

Plot No. 277, Kundan R. No. 903, 9th Floor,

Pratistha Bhavan, M.

Mansion, Agashi Road, Vs.

K. Road, Mumbai-

Virar (W), Dist-Thane,

400 020

Thane, Maharashtra-

401303

PAN/GIR No. AFDPB3867Q

(Applicant) (Respondent)

Assessee by Shri Subhodh Ratnaparkhi, Ld. AR

Revenue by Ms. Kavitha Kaushik, Ld. DR

Date of Hearing 11.12.2025

Date of Pronouncement 29.12.2025

आदेश / ORDER

PER MAKARAND VASANT MAHADEOKAR, AM:

This appeal is filed by the assessee against the order passed

by the Commissioner of Income-tax (Appeals)-47, Mumbai

[hereinafter referred to as “CIT(A)”], dated 24.06.2025, for

Assessment Year 2020–21, arising out of the assessment order

passed under section 143(3) of the Income-tax Act, 1961

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Jigna Kundan Bhatt

[hereinafter referred to as “the Act”] by the Assistant

Commissioner of Income-tax, Central Circle-1(1), Mumbai, dated

28.09.2021.

2. The facts of the case are that assessee is an individual. For

the year under consideration, the assessee filed her return of

income on 05.02.2021 declaring total income of Rs. 19,11,490/-

.A search and seizure action under section 132(1) of the Income-

tax Act, 1961 was carried out on 19.02.2020 in the case of M/s.

R.B. Tradelinks LLP along with its group concerns and partners.

The assessee was also covered under the said search action. The

case was selected for compulsory scrutiny.

3. The Assessing Officer observed that during the year under

consideration, the assessee had received unsecured loans

aggregating to Rs. 25,00,000/- from the following parties:

i.

M/s. Krisha Enterprises: Rs. 5,00,000/-

ii.

Shri Sharad Gandhi: Rs. 10,00,000/-

iii.

Shri Yash Sharad Gandhi: Rs. 10,00,000/-

4. The assessee was called upon to establish the identity and

creditworthiness of the lenders and the genuineness of the

transactions. According to the Assessing Officer, despite issuance

of notices and opportunities granted, the assessee failed to

furnish confirmations, copies of returns of income, bank

statements and other documentary evidences to substantiate the

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ITA No. 5265/Mum/2025

Jigna Kundan Bhatt

loans. The Assessing Officer held that the assessee failed to

discharge the onus cast upon her under section 68 of the Act and

accordingly treated the entire sum of Rs. 25,00,000/- as

unexplained cash credit.

5. During the course of search, jewellery valued at Rs.

57,83,972/- weighing approximately 1699.446 grams was found

in lockers and at the residence of the assessee. The Assessing

Officer noted that the jewellery was found in lockers registered in

the name of the assessee. The explanation of the assessee that

the jewellery belonged to various family members and was held as

family jewellery was not accepted for want of documentary

evidence. The Assessing Officer further observed that CBDT

Instruction No. 1916 dated 11.05.1994 deals with non-seizure of

jewellery and does not dispense with the requirement of

explaining the source of acquisition. Accordingly, the jewellery

was treated as unexplained investment under section 69A of the

Act.

6. The Assessing Officer observed that the assessee had

claimed deduction of Rs. 1,60,000/- under Chapter VI-A but

failed to furnish supporting documentary evidence during the

assessment proceedings. Accordingly, the claim was disallowed.

7. The assessment was completed under section 143(3) of the

Act determining the total income of the assessee at Rs.

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ITA No. 5265/Mum/2025

Jigna Kundan Bhatt

1,03,55,460/- after making above mentioned additions and

disallowance.

8. Aggrieved by the assessment order, the assessee preferred

an appeal before the CIT(A). Before the CIT(A), the assessee

submitted that the additions were made without proper

appreciation of facts and evidence and that sufficient opportunity

was not granted during the assessment proceedings.

9. In resp