2014 (5) TMI 775

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....ned assessment u/s. 153A and in passing the impugned assessment order, more so when there was no valid search in accordance with provisions of section 132 conduced in the case of the asseessee. 2. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in allowing a rebate of only 700 gms of jewelry in respect of the entire family and thereby upholding the addition made by the Ld. AO of the balance of 1232.8 gms. On account of unexplained investment in jewellery u/s. 69 of the I.T. Act, 1961. 3. In any view of the matter and in any case the order under appeal is bad in law and against the facts and circumstances f the case. 4. That the appellant craves the leave to add, amend, modify,....

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.... No. 1916 dated 11.5.1994 is only in respect of seizure of the jewellery. In these instructions the Authorised Officer were instructed not to seize the jewellery to the extent of 500 gms. per married lady member; 250 gms of jewellery per unmarried lady member and 100 gms. of jewellery per male member. These instructions have no relevance with the assessment proceedings. That during the assessment proceedings, the assessee did not give any explanation. Therefore, the AO has treated the entire jewellery as unexplained. The Ld. CIT(A) was quite fair and reasonable to allow rebate of 700 gms. of jewellery. She, therefore, submitted that no further relief is due to the assessee. 4. We have considered the arguments of both sides and perused th....