CBDT Instruction 1916 Applies to Taxation Too – ITAT Deletes Jewellery Addition Within Prescribed Limits

Ramnath Gupta Bysani Vs JCIT (ITAT Bangalore) The Bangalore ITAT in the case of Shri Ramnath Gupta Bysani dealt with addition of ₹1.03 crore as unexplained jewellery u/s 69B arising from a search, where the assessee relied on CBDT Instruction No. 1916 (11.05.1994). The AO and CIT(A) rejected the claim, holding that the instruction applies only to seizure during search and not for taxation. However, the Tribunal disagreed and held that the instruction provides a reasonable benchmark for explaining jewellery holdings, especially when supported by customary and family factors. The ITAT relied o...