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<h1>Appropriation of seized primary gold allows market value adjustment against tax arrears, subject to gold control confiscation rules.</h1> Primary gold seized in searches under section 132 enters Government custody and, because the Gold (Control) Act does not apply to Government possession, may be considered for appropriation of its market value towards income tax arrears; practical issues include prohibition on private sale, Mint accounting of value, requirement for international rate realisation, and the Gold Control Administrator's view that confiscated gold vested in the Central Government cannot be appropriated except where redemption on payment of fine returns value to the party.