Mukesh Mangla v. Principal Director of Income Tax ( Investigation ) and Anr.

Delhi HC19 May 2026W.P.(C)/9080/2024

Case brief

AI extract

What is this about?

Release of jewellery seized during income-tax search; Delhi High Court writ disposed of after deposit of tax demand and penalty; assessment order 30.03.2026; penalty proceedings concluded; no other proceedings pending; representation with seizure memo and identity proof; keywords: search and seizure, jewellery release, Principal Director of Income Tax (Investigation), W.P.(C) 9080/2024, seized 06.12.2021.

What did the court decide?

Release of the jewellery seized on 06.12.2021, to be ensured by respondent No.1 (Principal Director of Income Tax (Investigations)) preferably before 30.06.2026, upon the petitioner filing a representation with the seizure memo, valid proof of identity and a web copy of the order within seven days. ¶¶28

Mukesh Mangla Vs Principal Director of Income Tax ( Investigation ) and Anr. — Delhi HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

¶¶28

Issue for consideration

Whether the jewellery seized during the search ought to be released to the petitioner, the entire tax demand and penalty having been deposited.

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Court's answer

With the entire tax demand (Rs.73,350/-) and penalty (Rs.13,362/-) deposited and the respondents confirming that no other proceedings are pending, the Court held that the jewellery seized on 06.12.2021 is required to be released forthwith.

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Ratio / Principle

The writ petition was disposed of with a direction to respondent No.1, the Principal Director of Income Tax (Investigations), to ensure that the petitioner's jewellery is released as early as possible, preferably before 30.06.2026.

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Key takeaways

Implementation mechanism: the petitioner may file a representation before respondent No.1 enclosing a photocopy of the seizure memo, valid proof of identity and a web copy of the order, within seven days.ratio¶¶27

Detailed headnote1 paragraphs

High Court of Delhi (W.P.(C) 9080/2024, order dated 19.05.2026, Dinesh Mehta and Vinod Kumar JJ.) disposed of a writ petition challenging income-tax search proceedings after the petitioner deposited the entire tax demand (Rs.73,350/- on 17.04.2026) and penalty (Rs.13,362/- on 14.12.2025). With the respondents' counsel confirming on instructions that no other proceedings were pending against the petitioner, the Court directed respondent No.1, Principal Director of Income Tax (Investigations), to ensure release of the jewellery seized on 06.12.2021 (worth Rs. 24,22,763/-, of which all but Rs. 1,71,310/- had been treated as explained in the assessment order dated 30.03.2026) as early as possible, preferably before 30.06.2026, upon the petitioner filing a representation with a photocopy of the seizure memo, valid proof of identity and a web copy of the order within seven days.

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$~96

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- W.P.(C) 9080/2024

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MUKESH MANGLA .....Petitioner

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Through: Mr. Arvind Kumar, Adv.

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versus

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PRINCIPAL DIRECTOR OF INCOME TAX ( INVESTIGATION ) AND ANR .....Respondents Through: Mr. Vipul Agrawal, SSC

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CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR

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O R D E R % 19.05.2026

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On 22.04.2026, we have passed the following order :

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“1. The petitioner has challenged the search proceedings and sought a direction for release of the jewellery which was seized during search.

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2. He submitted that during the pendency of the present writ petition the Assessing Officer has passed an assessment order on 30.03.2026 and out of the jewellery worth Rs. 24,22,763/- the entire jewellery except jewellery worth Rs. 1,71,310/- has been treated as explained.

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3. He prayed that he would not press the case about the legality of the search, however, a direction be issued to the respondents to release the jewellery which was seized, while informing that he has deposited the entire demand (Rs.73,350/-) on 17.04.2026.

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4. Mr. Vipul Agarwal, learned Senior Standing Counsel for the respondents on the other hand submitted that the penalty proceedings are yet to be completed and unless the demand

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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 22/05/2026 at 12:26:30

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arising out of the penalty proceedings is finalized, no order for the release of jewellery be passed.

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5. The respondent-Assessing Officer is directed to calculate and inform Mr. Vipul Agarwal, the maximum amount of penalty which is likely to be imposed upon the petitioner, if he is not satisfied with the explanation furnished by the petitioner.

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6. At this juncture, it is informed by Mr. Arvind Kumar, learned counsel for the petitioner, that the petitioner has filed reply in response to the notice of penalty and nothing more is to be added by the petitioner; therefore in order to give a quietus to the dispute. Assessing Officer be directed to pass final order qua the penalty proceedings.

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7. List this case on 19.05.2026.

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8. The Assessing Officer is directed to pass final order in accordance with law, pursuant to the penalty notice issued to the petitioner.”

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Mr. Arvind Kumar, learned counsel for the petitioner at the outset submitted that the petitioner has deposited the tax demand of Rs.73,350/- on 17.04.2026 and penalty of Rs.13,362/- too has been paid on 14.12.2025.

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He prayed that since the entire demand has been deposited, the jewellery be ordered to be released forthwith. 4. Mr. Vipul Agrawal, learned Senior Standing Counsel accepted the fact that the amount of tax and penalty stands deposited. On the basis of instructions, he further submitted that as of today, no other proceedings are pending against the petitioner.

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Having regard to the facts noted above, we are of the view that the jewellery seized by the respondent on 06.12.2021 is required to be released forthwith, as the respondents cannot legitimately return the jewellery.

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This is a digitally signed order.

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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 22/05/2026 at 12:26:30

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We, therefore, dispose of the present writ petition while directing Principal Director of Income Tax (Investigations)-respondent No.1, to ensure that the petitioner’s jewellery is released as early as possible, preferably before 30.06.2026.

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The petitioner may file a representation before the respondent No.1 alongwith a photocopy of the seizure memo, valid proof of identity and a web copy of the order instant, within a period of seven days from today.

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The present Writ petition stands disposed of in above terms.

DINESH MEHTA, J

VINOD KUMAR, J

MAY 19, 2026/ ss

This is a digitally signed order.

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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 22/05/2026 at 12:26:30

Mukesh Mangla v. Principal Director of Income Tax ( Investigation ) and Anr.

Case brief

What is this about?

What did the court decide?

Mukesh Mangla v. Principal Director of Income Tax ( Investigation ) and Anr.

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

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Procedural history

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