ITA 529/2026 $~6 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 529/2026 & CM APPL. 43607/2026 NIRMAL PURI .....Appellant Through: Mr. Rajat Navet and Mr. Kushagra Pandit, Advocates. versus ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 26, NEW DELHI .....Respondent Through: Mr. Gaurav Gupta, SSC with Mr. Shivendra Singh and Mr. Yojit Pareek, JSCs. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE RAJNEESH KUMAR GUPTA O R D E R % 21.07.2026 1. Learned counsel for the appellant argued that the authorities below have erred in rejecting concurrently treating the small quantity of bullion (426 grams) to be unexplained. 2. Learned counsel for the appellant further argued that the appellant/assessee is 70 year old lady, residing with her family and that in a family set-up in an Indian society, a lady receives gold ornaments and jewellery not only from her parents but also from her in-laws and other family members, including son apart from her husband. 3. He submitted that the total gold found in the locker was 1242 grams, including gold ornaments belonging to the appellant as well as her This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 23/07/2026 at 12:00:58 ITA 529/2026 daughter-in-law, which cannot be said to be excessive. Yet, the Assessing Officer vide order dated 29.03.2022 found 426 grams of gold to be unexplained and made an addition in the hands of the appellant. Such addition, despite the satisfactory explanation furnished by the appellant, was affirmed by Commissioner of Income Tax (Appeals) vide order dated 16.07.2025 so also by Income Tax Appellate Tribunal vide order dated 23.12.2025. 4. Mr. Gaurav Gupta, learned Senior Standing Counsel for the respondent, submitted that all the authorities have concurrently held against the appellant. He pointed out that what was found in appellant’s locker was 4 gold bars of 24-carat and not gold jewellery. He pointed out that the authorities have treated the gold bars to be unexplained, while the ornaments have been held duly explained and no addition in that regard was made in the hands of the appellant/assessee. 5. Having heard learned counsel for the parties and considering the fact that the addition made in the hands of the appellant pertains to the value of the gold bars, we are of the view that no interference is warranted in the appeal that has been filed under Section 260A of the Income Tax Act, as no substantial question of law arises for our consideration. 6. The appeal is dismissed along with pending application. DINESH MEHTA, J RAJNEESH KUMAR GUPTA, J JULY 21, 2026/nd This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 23/07/2026 at 12:00:58