2020 (10) TMI 1338

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....oceeding under section 132 of the Act was carried at the residence of the assessee on 20.01.2014 at 237, Sukh Dev Vihar, New Delhi. 4. During the course of search, jewellery worth Rs. 1,07,79,839/- was found out of which jewellery worth Rs. 13,95,537/- was seized. During the course of assessment proceedings, assessee was asked to explain the source of jewellery found during the search to which assessee inter alia submitted that most of the jewellery was received by various members of the family especially females as gifts on various occasions and was part of their stridhan and the assessee also relied on the instruction No. 1916 dated 11.05.1994 issued by CBDT to contend the quantum of jewellary which is held by an individual is to be cons....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ion, he pointed out to the copy of the panchnama which is placed in the paper book which shows the quantity of the jewellery to be at 671.53 gms valued at Rs. 31,27,296/-. He further submitted that CIT(A) has given the credit of 600 gms of jewellery for the assessee and his wife but has not given any credit of the jewellery for his son though his son also stays with him. In support of his contention that the family consisted of himself, his wife and his son and they stay together, he pointed to the copy of the statement recorded at the time of search and specifically to answer to question no. 25 wherein it was submitted by the assessee that he was staying with the other family members and his son. He, therefore, submitted that if the correc....