Tax Dispute Over Unexplained Jewellery: Assessee Challenges 100% Taxation, Cites CBDT Instruction No. 1994 on Permissible Limits.

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....Unexplained jewellery - By no stretch of imagination if tax is at all due the same is equivalent to 100% value of the jewellery found. Furthermore, the Revenue authorities cannot also show ignorance of the permissible limit of jewellery holdings as prescribed by the CBDT Instruction No. 1994. Assessee has duly brought on record affidavits of the family members owning jewellery. Just because the claim is made otherwise then by revised return the said claim does not seize to be a claim to be adjudicated as long as the claim is made. - AT....