The Income Tax Appellate Tribunal (ITAT), Mumbai Bench, handed a partial victory to Anjani Ashok Parikh on September 1, 2026, striking down a ₹67.39 lakh tax addition. The assessing officer had flagged the jewellery value declared in her income tax return for assessment year 2021-22 as unexplained income under Section 69A. The tribunal rejected this classification, finding the department’s logic legally unsound.
The core of the dispute hinged on a gap in filing history. Parikh, who reported a total income of ₹10.21 crore from selling a Mumbai property for ₹106 crore, disclosed ₹67,39,949 in ancestral jewellery in Schedule AL. This was her first such disclosure, triggered by crossing the ₹50 lakh income threshold. The assessing officer reasoned that because Parikh had stopped filing wealth-tax returns after 1997-98, her wealth must have dropped below the threshold. From that silence, the officer inferred the jewellery was sold or disposed of, treating the entire amount as unexplained cash. No sale bills, bank credits, or transfer records ever emerged to support this claim.
The tribunal dismantled that chain of inference. Citing the absence of independent evidence, the panel noted that not filing a return only proves taxable wealth fell below the limit, not that specific assets vanished. Parikh had produced a robust documentary trail, including her 1997-98 wealth-tax return, valuation reports, and a 2015 family declaration detailing the distribution of ancestral ornaments among legal heirs. The judge concluded the department relied on assumption rather than fact.
The win wasn’t clean. The ITAT upheld a separate ₹12 lakh disallowance regarding brokerage fees. Parikh claimed ₹30 lakh in total brokerage for acquiring a residential flat, splitting the payment between an individual, his HUF, and a third party. The tribunal found the individual had already received ₹12 lakh in his personal capacity for the same transaction. Paying another ₹12 lakh to his HUF for identical services lacked justification, so that portion remained disallowed.
With the jewellery charge wiped out, Parikh’s effective tax liability for the year drops significantly. The remaining ₹12 lakh brokerage disallowance stands, but the bulk of the department’s aggressive assessment has been neutralized. The order leaves the tax department with no immediate avenue for appeal on the jewellery front, as the factual matrix was deemed insufficient to sustain the Section 69A addition.