CBDT non-seizure limit for gold jewellery applies to earlier seizures where the instruction governs the seizure situation.

The CBDT instruction on non-seizure limits for gold jewellery and ornaments was treated as relevant to the reasonableness of seizure by weight in light of social circumstances, rather than as a change in the value of the articles. Its benefit was held not to be confined to seizures made after the instruction's issuance, because the instruction operated with reference to the seizure situation itself. On that basis, the instruction was applied to the petitioner's case, and the balance of 10 tolas of gold could not be treated as unsatisfactorily explained merely because the seizure had occurred earlier.

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Issues: Whether the benefit of the CBDT instruction prescribing non-seizure limits for gold jewellery and ornaments could be denied merely because the seizure had taken place before the date of the instruction.

Analysis: The instruction was treated as governing the reasonableness of seizure of gold jewellery by weight, having regard to social circumstances, and not as altering the value of the articles. The Court held that the benefit of such an instruction could not be confined only to seizures made after its issuance, because the instruction was intended to operate with reference to the seizure situation and to extend the prescribed benefit even where the acquisition preceded the instruction.

Conclusion: The instruction applied to the petitioner's case, and the balance of 10 tolas of gold could not be treated as unsatisfactorily explained on the ground that the seizure was made earlier.

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