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Jewellery found in an assessee's locker was treated as explained where government-approved valuation reports established its age and ownership by the assessee and family members. CBDT Instruction No. 1916 serves as a guiding consideration for jewellery attributable to family members, assessed with reference to family status, customary gifts and inheritance, and the surrounding circumstances. On these facts, the explanation of source was accepted and the addition for unexplained jewellery was deleted.
Jewellery found in an assessee's locker was treated as explained where government-approved valuation reports established its age and ownership by the assessee and family members. CBDT Instruction No. 1916 serves as a guiding consideration for jewellery attributable to family members, assessed with reference to family status, customary gifts and inheritance, and the surrounding circumstances. On these facts, the explanation of source was accepted and the addition for unexplained jewellery was deleted.
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