CBDT jewellery guidelines limited search additions, with credit allowed only for family-attributable gold jewellery, not silver.

CBDT jewellery guidelines were applied to limit credit for jewellery found during search to the quantity normally attributable to specified family members. The Tribunal held that the circular covered gold jewellery only, not silver, and rejected the assessee's wider claim based on earlier wealth-tax declarations. Relief was allowed only for 650 grams of gold jewellery attributable to the assessee and family members, while the unexplained silver addition and the remaining jewellery addition were sustained.

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Issues: Whether the addition made towards unexplained investment in gold jewellery and silver found during search was sustainable, and to what extent credit could be allowed for jewellery held by the assessee and family members under the CBDT jewellery guidelines.

Analysis: The assessee's claim based on earlier wealth-tax declarations was not fully accepted. The Tribunal applied the CBDT circular on non-seizure of jewellery and followed its earlier view that credit can be given only to the extent of the jewellery quantum normally attributable to specified family members. The circular was held to cover gold jewellery alone and not silver. On that basis, only limited relief was warranted, and the unexplained silver addition remained justified.

Conclusion: The addition was sustained in part. Relief was granted only to the extent of 650 grams of gold jewellery attributable to the assessee and family members, and the balance addition remained undisturbed.

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