This is a recent ITAT Mumbai ruling from September 2026 that settles an important question: what happens when you disclose old jewelry for the first time in Schedule AL, and the department treats it as unexplained income under Section 69A?

Background

Anjani Parikh sold her 1/3rd share in a property at Juhu, Vile Parle West, Mumbai in January 2021 for around Rs. 35.33 crore. She filed her return reporting a long-term capital gain and claimed deductions under Section 54 and Section 54EC.

Since her income crossed Rs. 50 lakh for the first time that year, she was required to disclose her assets and liabilities in Schedule AL. She disclosed jewelry worth Rs. 67,39,949.

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This jewelry had two components:

• Ancestral jewelry inherited from her late father-in-law, mother-in-law, and their HUF, distributed among legal heirs around 2015 after a decades-long family dispute. Her share came to Rs. 46,94,547.
• Self-owned jewelry (stridhan) worth Rs. 20,45,402, which had been reported in her own Wealth Tax return back in AY 1997-98.

What the Tax Department said

The Assessing Officer asked for bills, vouchers, and bank statements to prove where the jewelry came from.

Since the jewelry was decades old, those documents were not available. The AO then drew an inference:

• Assessee had not filed a Wealth Tax return after AY 1997-98
• This means her taxable wealth must have fallen below the threshold
• Which means the jewelry must have been sold off before the year under review
• Therefore, the entire Rs. 67,39,949 is unexplained and taxable under Section 69A

The CIT(A) upheld this reasoning at the first appeal stage.

What the taxpayer argued

The assessee submitted a detailed documentary trail covering nearly three decades:

• Valuation report dated 31.03.1989 of the jewelry belonging to her late father-in-law and mother-in-law
• Wealth Tax return for AY 1997-98 disclosing self-owned jewelry of Rs. 19,55,105
• Wealth Tax workings for AY 2014-15 of the ancestral estates and HUF
• A declaration dated December 2022 signed by the eldest legal heir and counter-signed by all others confirming the 2015 family distribution
• A registered valuer's report from December 2022 certifying physical verification, no material change in quantity, with photographs attached

The argument was straightforward: you cannot tax jewelry as unexplained income merely because original purchase bills are not available, when decades of independent records establish both ownership and lineage.

What the court decided

The ITAT rejected the department's chain of inference entirely.

On the non-filing of Wealth Tax returns: not filing a return after AY 1997-98 only means taxable wealth was below the threshold. It does not mean a specific item of jewelry was sold. For that conclusion, the department needed independent evidence of a sale or receipt of sale proceeds. No such evidence existed.

On the absence of purchase bills: Section 69A requires that the assessee offers no explanation, or an unsatisfactory one. Where the explanation is backed by a consistent documentary record spanning decades, an addition cannot be sustained on suspicion alone.

The ITAT relied on three Supreme Court rulings from the 1950s that establish the same principle: suspicion, however strong, cannot replace proof.

The entire addition of Rs. 67,39,949 was deleted.

On the second issue involving brokerage of Rs. 12 lakh paid to Ajit Rao HUF as part of the Section 54 reinvestment cost, the Tribunal ruled against the assessee. The Karta of that HUF had already been separately paid Rs. 12 lakh in his individual capacity for the same transaction. Since brokerage is a personal service and the same individual had already been fully compensated, the additional payment routed through the HUF was treated as gratuitous. That disallowance was upheld.

Key takeaway

If you are disclosing jewelry in Schedule AL for the first time because your income crossed Rs. 50 lakh, the department can question the source. But the standard is not about producing 30-year-old bills. What matters is whether you can establish ownership and lineage through consistent historical records.

Wealth Tax returns, valuation reports, family settlement documents, and a registered valuer's physical verification can together be sufficient. The department cannot assume a sale simply because you stopped filing Wealth Tax returns.

On the HUF brokerage point: paying the same person twice for the same service, once individually and once through his HUF, will not hold up. The second payment will be disallowed.

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This is a recent ITAT Chennai case that settles an important question for online gamers who ended up losing money net-net but still received a massive tax demand.

Background

Srither, a taxpayer from Virudhunagar, Tamil Nadu, played online games on Gameskraft Technologies during FY 2021-22.

Gross winnings credited to his gaming wallet: Rs. 2,44,50,134

Total buy-in amounts paid to play: Rs. 2,74,96,660

Net result: A loss of Rs. 30,56,491

Despite the actual loss, the tax department received information from Gameskraft showing gross winnings of Rs. 2,44,64,534. The AO treated this entire amount as taxable income under Section 115BB and made a large addition. The CIT(A) confirmed this view.

What the Tax Department said

The department took a straightforward position.

Gameskraft reported gross winnings of over Rs. 2.44 crore flowing into the assessee's wallet

This entire amount was added as income from other sources

No deduction for buy-in costs was allowed since Section 58(4) bars expenditure deductions against gaming winnings

The CIT(A) agreed, holding that Section 115BB covered online games and that the new Section 115BBJ introduced in 2023 did not imply online games were untaxed before

What the taxpayer argued

The assessee's lawyer made two arguments, one primary and one fallback.

Primary argument: Online gaming involves skill, not chance. Citing a Madras High Court ruling in GR Karthikeyan, the argument was that winnings from skill-based activities fall outside Section 2(24)(ix) entirely

Fallback argument: Even if taxable, only real net winnings should be taxed. Gameskraft's own records showed buy-ins of Rs. 2.74 crore against gross credits of Rs. 2.44 crore, resulting in an actual loss. Taxing gross wallet credits ignores the basic concept of income.

The assessee also pointed to an earlier Bengaluru ITAT ruling involving the same platform and same assessment year, which had taken the same net-income view.

What the court decided

The Tribunal rejected the primary argument. The Supreme Court had already overruled the Madras High Court in GR Karthikeyan, holding that skill-based winnings are still taxable income.

However, on the real income question, the Tribunal sided with the assessee.

The ITAT held that every credit into a gaming wallet is not income. Repeated circulation of funds, buy-ins, and redeployment of winnings in subsequent rounds do not themselves constitute taxable receipts.

The Finance Act 2023 provisions introducing Section 115BBJ and 194BA, which explicitly tax only net winnings, were held to be clarificatory, not a new principle. They codified what was always the correct interpretation of income under the Act.

Earlier horse racing decisions from the Kolkata and Delhi benches, which allowed netting of buy-in costs against winnings, were applied by analogy to online gaming.

The Tribunal noted that Gameskraft itself had not deducted any TDS, which supports the assessee's position that there were no net winnings at all.

The AO's addition of Rs. 2,44,50,134 was directed to be deleted in full.

A similar view had also been taken by the Hyderabad ITAT in a case involving the same platform for the same year.

Final outcome

Appeal allowed

Addition of Rs. 2,44,50,134 deleted

Only real net winnings from online gaming are taxable, not gross wallet credits

Key takeaway

If you played on platforms like Gameskraft and your total buy-ins exceeded your total winnings, the net loss position means there is no taxable income.

The tax department cannot pick only the gross credits from the gaming platform's data while ignoring the corresponding buy-in amounts from the same records.

The 2023 amendments formalized the net-winnings principle. But as this ruling makes clear, the principle applied even before those amendments came in.

This is a recent ITAT Delhi ruling from September 2026 that highlights a frustrating but important situation. The assessee was right, the officer knew he was right, and still denied the correction. Here is what happened.

Background

Ajay Kumar Bakaya, a resident senior citizen, had invested ₹3 crore in tax-free bonds back in February 2013.

IIFCL 8.48% Tax Free Bonds: ₹2 crore
REC 8.46% Tax Free Bonds: ₹1 crore

Interest on both these bonds is fully exempt under Section 10(15)(iv)(h) of the Income Tax Act.

For AY 2022-23, he earned ₹25.42 lakh as interest on these bonds. But by mistake, this exempt income was entered under "Income from Other Sources" as taxable income. He paid ₹9.91 lakh extra tax as a result.

To be clear, he had correctly shown this income as exempt in six other assessment years. This was a one-year filing error.

What the Tax Department said

By the time the assessee noticed the mistake, the deadline to file a revised return had already passed.

He filed a rectification application under Section 154, asking for the correction and a refund of ₹9.91 lakh.

The Assessing Officer rejected the application. The reason given was that a new claim for deduction cannot be made through a rectification application. Only a revised return would have been the correct route, and that window had closed.

The AO cited the Supreme Court's Goetze (India) Ltd. judgment to support this position.

The CIT(Appeals) also upheld the rejection.

What made this more problematic: the AO's own order clearly stated that the interest income "was erroneously added as taxable income while filing the tax return." He acknowledged the mistake but still refused to correct it.

What the taxpayer argued

The assessee made three key arguments before ITAT.

First, this was not a fresh claim. The bonds and the interest income were already disclosed in the original return. The only error was placing exempt income in the wrong column. That is a correction of an apparent mistake, not a new deduction claim.

Second, Goetze (India) Ltd. does not apply here. That ruling restricts Assessing Officers from entertaining fresh claims not made in the return. It does not restrict appellate authorities. ITAT has full power to consider such corrections.

Third, Article 265 of the Constitution says no tax can be collected except by authority of law. CBDT Circular No. 14 of 1955 also places a duty on tax authorities to help taxpayers claim legitimate reliefs, not deny them on technical grounds.

What the court decided

ITAT Delhi allowed the appeal in full.

The Tribunal held that this was a clear mistake apparent from the record, not a fresh claim. The AO had already acknowledged this in writing.

It relied on the coordinate bench ruling in Kapil Dev Nikhanj (2025), which clarified that Goetze (India) Ltd. only limits AOs and not appellate authorities. The correct amount of tax must be collected from the right person as per law. Revenue cannot benefit from a taxpayer's inadvertent error when the statute specifically exempts that income.

ITAT directed the AO to treat ₹25.42 lakh as exempt under Section 10(15)(iv)(h) and refund ₹9.91 lakh along with applicable interest.

Key takeaway

If you miss the revised return deadline, a Section 154 rectification can still work, but only when the error is clear from the record itself.

An AO rejecting such a correction, even after acknowledging the mistake, is not the end of the road. ITAT has full power to step in.

Goetze (India) Ltd. is often misapplied. It restricts AOs, not appellate tribunals. This distinction matters.

And practically: always double-check which column your exempt income goes into before filing. A wrong column entry can cost you a refund for years.

I closed my GST registration in 2020. I missed the deadline for the final return, GSTR-10, but filed it in November 2024 and paid ₹20,000 in late fees.

Now I’ve received a notice proposing another ₹50,000 penalty. It says I have not filed GSTR-10, although I filed it almost two years ago. I have the filed return showing the filing date and payment.

Has anyone dealt with this? What should I write in my reply, and which documents should I attach? Do I need to attend a hearing? I want to respond properly before the deadline.

So I got my hike letter and was pretty happy at first. 9.41% on 12.53 LPA, so I'm going to around 13.7 LPA from October.

Then I actually sat down and did the math. Till 12.75L the new regime basically gives you zero tax because of the rebate. The moment you cross it, tax starts. So all my extra money is going straight into the tax slab. My monthly gross goes up by around 9.8k, but the take-home only goes up by about 2.7k.

Koi faida nahi hua bhai.

All those reels of people crying about Indian tax, I used to scroll past them. Now I'm the one crying.

I read that employer NPS (80CCD(2)) can bring the taxable income back down, and my company has the option. Has anyone here done it? Is it actually worth locking the money till 60 just to save the tax? Or is there something else I'm missing?

Also, did anyone else get a small hike and end up in the same situation? Just want to know if I'm the only one feeling this.