Joint Family Gold & VDIS Explain Jewellery Addition: ITAT Ranchi

Anju Kumari Vs ACIT (ITAT Ranchi)

A Joint Locker Is Not a Sole Ownership Certificate: ITAT Deletes Gold Additions

The controversy

Gold kept together by a joint family cannot mechanically be treated as the unexplained asset of one member merely because she jointly operates the locker. The Ranchi Tribunal applied this approach while deleting two additions under section 69A, aggregating to ₹27,53,786, relating to gold jewellery and bullion.

The decision turned on purchase invoices, an accepted VDIS declaration and the Department’s failure to properly correlate the assets with individual family members.

The search and the additions

A search under section 132 was conducted in the Dorabji Group on 12 January 2023 and subsequent dates. Anju Kumari, who declared income from salary, house property and other sources, filed her return showing total income of ₹4,01,660.

During the search, jewellery was found at the residence and in bank lockers. The Assessing Officer attributed 693.51 grams of gold jewellery to the assessee. After allowing 500 grams with reference to CBDT Instruction No. 1916, he treated the remaining 193.51 grams as unexplained and added ₹10,79,786 under section 69A.

A separate addition of ₹16,74,000 was made for 300 grams of gold bullion, comprising three pieces weighing 100 grams each.

The CIT(A) confirmed both additions, finding that the excess jewellery and the source of investment in the bullion had not been satisfactorily explained.

Purchase invoices could not be ignored

The assessee furnished purchase invoices from Tanishq and P.C. Jewellers covering 197.91 grams of jewellery, exceeding the disputed quantity of 193.51 grams. According to her submissions, these purchases had been made by her or her spouse during 2011–2017, from disclosed sources.

She argued that the CIT(A) had not questioned the genuineness of the invoices or the source of payment. The objection was essentially that there was no exact, one-to-one correlation between the invoices and the articles found during the search.

The assessee explained that the descriptions, purity and weight ranges corresponded with the valuation records. Demanding identification of every old ornament at the level of an individual serial number was, according to her, an unrealistic evidentiary standard.

She also relied on Ram Prakash Mahawar v. DCIT, arguing that jewellery supported by actual purchase evidence should be considered separately from the benefit claimed under CBDT Instruction No. 1916.

The family’s jewellery was stored together

The household comprised the assessee, her husband, mother-in-law and father-in-law. Jewellery belonging to these members was commonly kept together at the residence or in bank lockers.

The assessee’s objection was therefore fundamental: the Department had considered the jewellery collectively for discovery, but substantially treated it individually for making the addition.

The Tribunal noted the presence of two female and two male family members, the pooled storage arrangement and the purchase invoices. In that setting, it found the disputed difference of 193.51 grams sufficiently explained.

It also observed that the Assessing Officer had failed to identify and correlate the jewellery with the persons residing together.

The bullion had a VDIS history

The 300 grams of bullion was found in a locker jointly held by the assessee and her father-in-law, Kapil Deo Lal.

The assessee relied on a disclosure made by her mother-in-law, Chandrawati Devi, under the Voluntary Disclosure of Income Scheme, 1997, which had been accepted by the Department.

Her submissions explained that the declaration covered 42 gold coins of one tola each, approximately 489.7 grams, whereas the search revealed three pieces totalling 300 grams. She argued that a change in denomination or physical form over more than 25 years did not, by itself, establish a fresh unexplained acquisition.

She additionally pointed to inconsistent ownership descriptions in the search and valuation papers. Joint access to the locker, she maintained, could not establish her exclusive ownership of its contents.

The Tribunal’s findings

The Tribunal accepted that the bullion was covered by the mother-in-law’s previously accepted VDIS declaration. It also found that the Assessing Officer had failed to properly correlate the three bullion pieces with individual family members.

Recognising the common practice of joint families keeping jewellery and bullion together, the Tribunal held that the overall benefit associated with CBDT Instruction No. 1916 could not be denied without appropriately identifying ownership.

Both additions were deleted, and the appeal was allowed.

Author’s comments

The practical message is clear: the name on a locker does not conclusively identify the owner of every article inside it. Family composition, purchase records, past disclosures and the Department’s own inventory must be examined together.

A numerical correction is necessary when citing this order. Its concluding paragraph mentions 200 grams per male member, while the reproduced earlier decision mentions 400 grams for a married woman. The actual Instruction specifies 500 grams per married woman, 250 grams per unmarried woman and 100 grams per male member. These are non-seizure guidelines, rather than a statutory ceiling on explained ownership.

The decision is therefore best relied upon for its combined appreciation of family ownership and documentary evidence, without reproducing those numerical discrepancies.

Gold may be stored collectively; an addition still requires a properly examined explanation and attribution.

Cases Discussed

1. Ram Prakash Mahawar Vs DCIT (ITAT Jaipur), [2020] 115 taxmann.com 241 — Relied upon by the assessee for the proposition that jewellery otherwise explained through documentary evidence is to be considered separately and the benefit of CBDT Instruction No. 1916 does not take away the benefit available for explained jewellery.

2. Kuruganti Srivalli Vs ACIT, Central Circle, Dhanbad (ITAT Ranchi), ITA No. 84/Ran/2024, order dated 18/12/2025 — Relied upon before and considered by the Tribunal concerning jewellery/bullion, family holding and CBDT Instruction No. 1916.

3. Kishorbhai V. Sakaria (Rameshchandra R. Patel), 89 ITD 203 — Cited by the assessee concerning the benefit attributable to jewellery/valuables of family members under CBDT Instruction No. 1916.

4. Manila S. Dave, 117 Taxman 23 (Ahd.) — Cited along with Kishorbhai V. Sakaria on the treatment of jewellery belonging to family members.

FULL TEXT OF THE ORDER OF ITAT RANCHI

1. This appeal by the assessee is directed against the order of the Commissioner of Income Tax (Appeals), Patna-3, Patna [in short, the ld. CIT(A)] dated 27/02/2026 for the Assessment Year (AY) 2023-24, wherein the assessee has raised following grounds of appeal:

“1. That on the facts and in the circumstances of the case and in law, the Ld. Commissioner of Income-tax (Appeals) erred in law and on facts in sustaining the addition of Rs 10,79,786/- made by the Ld. Assessing Officer under Section 69A of the Act by treating the alleged excess gold jewellery as unexplained, without properly appreciating the explanation furnished by the appellant along with the supporting purchase invoice evidencing the source of the said jewellery.

2. That on the facts and in the circumstances of the case and in law, the Ld. Commissioner of Income-tax (Appeals) erred in law and on facts in sustaining the addition of Rs 16,74,000/- made by the Ld. Assessing Officer under Section 69A of the Act on account of gold bullion found in a locker jointly held with a family member, without properly appreciating the documentary evidence demonstrating that the said gold formed part of the disclosure made by the mother-in-law of the appellant under the Voluntary Disclosure of Income Scheme, 1997 and also ignoring the fungible nature of gold.

3. That on the facts and in the circumstances of the case and in law, the Ld. Commissioner of Income-tax (Appeals) erred in law and on facts in sustaining the addition made under Section 69A by the Ld. Assessing Officer without appreciating that the gold bullion in question belonged to the mother-in-law of the appellant, and that ownership cannot be attributed to the appellant merely on the basis of possession OR joint operation of the locker in the absence of any corroborative material.

4. That on the facts and in the circumstances of the case and in law, the Ld. Commissioner of Income-tax (Appeals) erred in law and on facts in sustaining the addition under Section 69A of the Act without appreciating that the said provision expressly refers to, if any books of account, and, therefore, in the absence of any books of account maintained by the appellant, invocation of Section 69A was legally untenable.

5. That the appellant craves leave to add, alter, amend, modify OR withdraw any of the above grounds of appeal at OR before the time of hearing.”

2. Facts of the case, in brief, are that a search and seizure operation under Section 132(1) of the Income Tax Act, 1961 (in short, the Act) was carried out on 12/01/2023 and on subsequent dates in the residential as well as business premises of Dorabji Group of cases. The return of income was filed by the assessee under Section 139 of the Act on 29/12/2023 declaring total income at ₹ 4,01,660/- The assessee has declared income from salary, house property and income from other sources. The case of the assessee was selected for compulsory scrutiny being the search and seizure case. Subsequently, notice under Section 143(2) of the Act was issued alongwith questionnaire. Subsequently, assessment order under Section 143(3) was passed on 21/03/2025 in which two additions have been made by the Assessing Officer. First addition was made on account of jewelry found in the residential premises and in locker maintained by the assessee in Punjab & Sindh Bank and Bank of Baroda, Jamshedpur. It has been mentioned in the assessment order that the assessee has claimed to be the owner of 693.51 grams gold jewellery, however, the assessee could explain the ownership of jewellery up to 500 grams only and could not explain the difference of 193.51 grams of gold jewellery and therefore, the Assessing Officer treated this as unexplained money of the assessee under Section 69A of the Act by applying a rate of ₹ 5,580 X 193.51 which is equal to ₹ 10,79,786/- (183.51 X ₹ 5,580/-). Further the Assessing Officer also added a sum of ₹ 16,74,000/- under Section 69A of the Act on account of unexplained money in the investment of gold bullion (coins) weighing 300 grams.

3. Aggrieved by the order of the Assessing Officer, the assessee filed appeal before the ld. CIT(A), who vide the impugned order dated 27/02/2026 confirmed the additions made by the Assessing Officer on the ground that during the period under consideration, the assessee was found to be the owner of the jewellery beyond the permissible limit of 500 grams and was not able to explain the difference. The ld. CIT(A) further, confirmed the addition of ₹ 16,74,000/- under Section 69A of the Act on the ground that the assessee could not explain the source of investment in the purchase of bullions.

4. Aggrieved by the order of the ld. CIT(A), the assessee is in appeal before this Tribunal.

5. During the appellate proceedings before us, the assessee has submitted as under:

A. Submissions on Ground Nos. 1 to 3 (Excess Gold Jewellery – Rs. 10,79,786/-)

A.1 The Ld. CIT(A) did not doubt genuineness or source of the invoices

It is respectfully submitted that a bare perusal of the impugned order shows that the Ld. CIT(A) has nowhere doubted (a) the genuineness of the purchase invoices issued by Tanishq and PC Jewellers, (b) the fact that payments for such purchases were made through disclosed sources (cash withdrawals/bank), or (c) the arithmetical fact that the invoiced quantity (197.91 gm) exceeds the disputed quantity (193.51 gm). The sole basis for confirming the addition is the finding that “no one-to-one correlation” stands established between the invoices and the jewellery physically found at the time of search. It is submitted that this finding, with respect, does not meet the requirement of law and is factually incorrect when the invoices are read together with the Panchnama-cum-Valuation Report.

A.2 Reconciliation of invoices with the Panchnama/Valuation Report (Annexure C)

The Valuation Report dated 13.01.2023 (Form O-8A, Annexure C) prepared by the Registered Valuer records the jewellery found in Locker No. 87 (Punjab & Sind Bank) and Locker No. 494A (Bank of Baroda) item-wise, by category (Chain, Har, Ring, Earrings, Bangles, Locket), gross weight, net weight and purity.

The following table sets out the correlation between the purchase invoices relied upon by the Appellant and the categories of jewellery recorded in the said Valuation Report:

Note: The categories of jewellery (chain, bangles, rings, earrings) recorded against Locker No. 87 and the residence in the Valuation Report at Annexure C are of the same description, purity (22KT) and comparable weight-range as the items purchased under the above invoices. The Ld. AO has himself, at Para 6 of the assessment order, accepted 693.51 gm of jewellery as being that of the Appellant (i.e., has not disputed possession/ownership qua the Appellant of the jewellery so found) the dispute is confined only to source/explanation of 193.51 gm out of such 693.51 gm. Once invoices for 197.91 gm of gold jewellery of matching description and purity, purchased by the Appellant/her spouse over 2011-2017, are on record and their genuineness is not questioned, the requirement of Section 694 that the Appellant offer a satisfactory explanation of source stands discharged, the law does not require an item-serial-number-level correlation between an invoice of a fungible commodity such as gold jewellery, purchased years before search, and the specific piece found at the time of search-such a standard of proof is neither practicable nor warranted by Section 694.

A.3 Instruction No. 1916 and documentary proof operate cumulatively

It is submitted that the Ld. CIT(A)’s observation that “it is not a legal position that upto 500 grams no bills or explanation is required and beyond this quantity…jewellery found in excess of 500 grams shall be treated as explained” conflates two independent and cumulative protections available to an assessee: (a) the presumptive non-seizure/non-addition benefit under CBDT Instruction No. 1916, and (b) actual documentary proof of purchase. Reliance is placed on the decision of the Jaipur Bench of the Tribunal in Ram Prakash Mahawar vs. DCIT, Central Circle, Alwar [2020] 115 taxmann.com 241 (Jaipur – Trib.), wherein it was held that where acquisition of jewellery is explained with proof, such quantity is to be allowed separately and over and above the quantity permitted under CBDT Instruction No. 1916 dated 11.05.1994. The purpose of the Instruction is to grant relief in respect of unexplained jewellery up to the prescribed limit; it was never intended to operate as a ceiling beyond which even documented and explained jewellery becomes taxable.

It is further submitted that the source of funds for the said purchases stands independently corroborated by the Appellant’s consistent history of income (ranging from Rs. 4,07,380/- to Rs. 4,60,020/- for AYs 2018-19 to 2022-23, all accepted as returned) and documented cash withdrawals over the years 2016-17 to 2022-23, as tabulated in the submissions before the Ld. CIT(A).

B. Submissions on Ground Nos. 4 to 7 (Gold Bullion – Rs. 16,74,000/-)

B.1 The Department’s own contemporaneous search records are mutually inconsistent as to ownership, and none attributes exclusive ownership to the Appellant

It is respectfully submitted that the addition of Rs. 16,74,000/- suffers from a basic infirmity going to jurisdiction and the identification of the correct assessee. This is borne out not merely by the Appellant’s explanation but by the Department’s own papers drawn contemporaneously with the search, which are set out and compared below

It is submitted that no document generated by the search/valuation process itself names the Appellant as the sole or exclusive owner of the bullion. At the very highest, she is described as a ‘co-owner’ of the locker (a fact about the receptacle, not the asset), and jointly named along with her father-in-law in the seizure inventory (Annexure J). The Department’s own valuer, on the other hand, names the Appellant’s husband as owner. These are irreconcilable attributions within the Revenue’s own record, generated on the same day (13.01.2023) in the course of the very same search. Where the Revenue’s own contemporaneous documents are at variance with each other on the question of ownership, it is not open to the Ld. AO to resolve that inconsistency by simply loading the entire value onto the person who happened to hold the locker key jointly, without any further inquiry into the claims recorded in the Revenue’s own papers pointing to the father-in-law and/or husband.

B.2 Further corroboration – joint locker with father-in-law, and VDIS declaration of mother-in-law

It is further submitted that consistent with the above, the locker (No. 87, Punjab & Sind Bank) was, as the Panchnama itself confirms, jointly held by the Appellant and her father-in-law, Shri Kapil Deo Lal not by the Appellant and her husband. The Appellant had, before the lower authorities, also placed on record that the bullion is traceable to a disclosure made by her mother-in-law, Smt. Chandrawati Devi, under the Voluntary Disclosure of Income Scheme (VDIS), 1997 (Annexure B), a disclosure accepted and certified by the Commissioner of Income Tax, Ranchi, with tax paid thereon.

Taken together with the Department’s own inconsistent attribution of ownership (Panchnama Annexure J – Kapil Deo Lal and Appellant jointly; Valuer’s Form O-8A-Rajesh Kumar Lal), it is submitted that there exist at least three plausible, identifiable and separately assessable persons (the father-in-law, the husband, and the mother-in-law) to whom the bullion is properly referable, and no material has been brought by the Revenue to exclude all three in favour of fastening 100% of the addition on the Appellant alone.

At no stage have the Ld. AO or the Ld. CIT(A) recorded a specific finding, based on positive material, that the bullion belongs, in beneficial ownership, to the Appellant herself, as distinct from her father-in-law, husband or mother-in-law. The addition has been made in the Appellant’s hands solely because the physical asset happened to be found in a locker to which she had joint access a basis that, with respect, is legally insufficient and is, moreover, contrary to the Department’s own seizure and valuation papers.

It is submitted that even if the Ld. CIT(A)’s reasoning based on the statement u/s 132(4) is taken at face value, that very statement (as recorded in the assessment order itself) supports the Appellant’s case that the bullion was purchased by, and hence belonged to, her husband Shri Rajesh Kumar Lal – a separately assessed person before the very same Department, and a person named as owner in the Department’s own Valuer’s Report. The Revenue cannot, on one hand, rely on that very statement to build its case, while disregarding its substance (that the bullion belonged to the husband) in fastening the addition on the Appellant. At the highest, if the Revenue was of the view that none of the explanations of ownership was acceptable, the addition, if warranted at all, ought to have been considered in the hands of the person(s) to whom the asset stands attributed on the Department’s own record not in the hands of the Appellant, who has consistently disclaimed exclusive beneficial ownership and who is, at the highest, described even by the Revenue’s own papers as no more than a co-owner/joint claimant.

B.3 VDIS, 1997 disclosure and fungibility of gold

The Ld. CIT(A) has confirmed the addition additionally on the ground that the VDIS certificate (Annexure B) discloses 42 gold coins of 1 tola (approx. 11.66 gm) each-i.e. an aggregate of approximately 489.7 gm whereas 3 gold bars/coins of 100 gm each (300 gm) were found during the search, and that “the said bullion was not found” in the form disclosed. It is submitted that this variance in physical form, occurring over a gap of over 25 years (1997 to 2023), does not by itself displace the explained source of the gold. Gold is a fungible commodity, and conversion of old coins into bars/coins of a different denomination, whether for convenience, safekeeping, or otherwise, is a matter of common experience and does not extinguish the explanation regarding source once a valid disclosure exists. The quantity found (300 gm) is, in fact, well within and less than the quantity originally disclosed (approx. 489.7 gm), which further supports rather than contradicts the Appellant’s explanation.

In any event, and without prejudice to the above, it is submitted that this aspect of reconciliation of form pertains squarely to the explanation of the declarant, Smt. Chandrawati Devi, whose disclosure is being relied upon, and cannot be read as evidence of undisclosed acquisition by the Appellant, who is a stranger to the VDIS declaration and has never claimed the bullion as her own.

B.4 Suspicion cannot take the place of proof; onus on Revenue to identify correct assessee

It is a settled principle that an addition cannot be sustained merely on suspicion, conjecture or surmise, and that where an asset found during search is attributed by the assessee to an identified third party with a plausible and, in this case, documented explanation, the burden shifts to the Revenue to disprove such explanation with positive material, or to proceed against the person so identified. No such exercise has been undertaken qua Shri Rajesh Kumar Lal or Smt. Chandrawati Devi in the present case.

Reliance is placed on the principle applied by the Coordinate Benches in the context of CBDT Instruction No. 1916 itself in Kishorbhai V. Sakaria (Rameshchandra R. Patel), 89 ITD 203 and Manila S. Dave, 117 Taxman 23 (Ahd.), wherein it was held that the benefit/character attached to jewellery/valuables of family members cannot be denied merely on a technical or narrow reading of possession, and that the intent behind such provisions/instructions to avoid needless additions in the hands of a person where the asset is properly referable to another identified family member.

It is accordingly prayed that the addition of Rs. 16,74,000/- be deleted in the hands of the Appellant, the Department being at liberty, if so advised and in accordance with law, to examine the matter in the hands of the person(s) to whom the asset has been attributed on the Department’s own record.

C. General

It is submitted that both additions are based on an overly technical appreciation of the evidence and surmise, without any positive material brought on record by the Revenue to displace the Appellant’s explanation. The additions are, therefore, liable to be deleted in the interest of justice.

PRAYER

In view of the foregoing, it is most respectfully prayed that this Hon’ble Tribunal may be pleased to:

(a) delete the addition of Rs. 10,79,786/- made u/s 69A r/w 115BBE on account of gold jewellery;

(b) delete the addition of Rs. 16,74,000/- made u/s 69A r/w 115BBE on account of gold bullion; and

(c) grant such other and further relief as this Hon’ble Tribunal may deem fit in the facts and circumstances of the case.”

The appellant has also enclosed the evidence for the purchase of the jewellery and also the certificate received by the assessee under Section 68(2) of the Act, voluntary disclosure of income scheme 1997 in support of this claim that jewelries and the bullions have been purchased from the disclosed sources and wherever it was undisclosed, it was declared under VDIS Scheme, 1997.

The ld. AR has placed reliance on the order of the Coordinate Bench of this Tribunal in ITA No. 84/Ran/2024 for the A.Y. 2021-22 order dated 18/12/2025 in the case of Kuruganti Srivalli vs. ACIT, Central Circle, Dhanbad wherein the coordinate Bench has held as under:

“6. We, after considering the rival submissions and perusing the material available on record, we find that the total gold found in the possession of the assessee during the search was 300 grams, which is within the permissible limit of 400 grams prescribed for a married woman. In the present case of assessee addition was made, merely because the jewellery was converted into solid gold form, no adverse inference can be drawn. Similarly, the quantity of silver found, valued at 1,46,000, is also within reasonable limits. After considering the rival submissions and perusing the material available on record, we find that the total gold found in the possession of the assessee during the search was 300 grams, which is within the permissible limit of 400 grams prescribed for a married woman. Merely because the jewellery was converted into solid gold form, no adverse inference can be drawn. Similarly, the quantity of silver found, valued at 1,46,000, is also within reasonable limits. CBDT Instruction No. 1916 dated 11.05.1994 provides that a married woman is entitled to possess up to 400 grams of gold without any adverse inference. The said gold may be held either in the form of jewellery or in any other form, including gold biscuits, since the Instruction does not restrict the form in which gold is kept. Merely because the jewellery has been converted into solid gold / gold biscuits, it cannot be presumed to be unexplained or in excess of the permissible limit. So long as the quantity remains within 400 grams, no addition can be made and no adverse view can be taken under the Income-tax Act. Moreover, for A.Y 2020-21, jewellery, bullion etc. was disclosed by the assessee of Rs. 59,21,500. Out of the said jewellery, jewellery valued at Rs.16,10,000/- which was in the possession of assessee at the time of search operation, while the remaining jewellery was kept with her mother-in-law at her native place for safe custody. This factual position is clearly recorded in the assessment order itself at page no.3 paragraph 9. The said disclosure demonstrates that the assessee was in possession of substantiating jewellery already reflected in the return of income of earlier year. In view of the above facts and the settled legal position, we hold that the assessee did not exceed the prescribed limits under the Act. Accordingly, the addition of ₹ 14,64,600 on account of gold and ₹ 1,46,000 on account of silver is unsustainable and liable to be deleted. We therefore direct the Assessing Officer to delete the entire addition made on account of gold and silver. Accordingly, the appeal filed by the assessee is allowed.”

6. On the other hand, the ld. Sr. DR supported the orders of the lower authorities.

7. We have carefully considered the facts of the case, rival submissions and the judicial decisions on which reliance was placed. It is found that two additions have been made by the Assessing Officer. First addition of ₹ 10,79,786/- was made on account of difference of 193.51 grams of gold jewelry found in the residential premises and the bank lockers in Punjab & Sindh Bank and Bank of Baroda, Jamshedpur, the source of which couldn’t be explained by the assessee. After going through the impugned order and the submissions made by the appellant, it is found that the jewellery were found and seized during the search and seizure operation conducted in the residential premises as well as bank lockers jointly owned by the assessee and her family members. That there was a difference of 193.51 gms. Gold after giving due exemptions as per the CBDT instruction No. 1916 which allows a lady to hold 500 gms of gold jewellery as reasonable. The appellant’s counsel in his written submission has submitted that the assessee is having a joint family and all the jewellery are mostly put together either in the residential premises or in the bank lockers. The family members consist of husband of the assessee, her mother-in-law and father-in-law. Thus, the difference of 193.51 gms. is not much. The Assessing Officer could not make addition on the basis of individual jewellery held by each family members. It was also submitted that the source of total jewellery aggregating 693.51 gms only exemption of 500 gms was given by the Assessing Officer as per the CBDT Instruction No. 1916 dated 11/05/1994 while there were two ladies and two male members were in the family. Besides that, the assessee was able to give the source of investment in this jewellery by producing the invoices of the jewllery purchased either from Tanishq or from P.C. Jewellers so considering the members in the family, the difference of 193.51 gms is sufficiently explained. Further, regarding the gold bullions weighing 300 gms found in the bank locker No. 7 in Punjab & Sindh bank, the Assessing Officer added the same on the ground that the source of investment in 300 gms gold, value of which was determined at ₹ 16,74,000/- by the approved valuer, again was dully explained as the same was declared under VDIS declaration of 1997 by the father in law and mother in law of the assessee which was duly accepted by the department. It was further submitted that the Assessing Officer has not made any co-relation with the jewellery found with each members of the family and therefore, the addition made in the hands of the assessee cannot be sustained. The appellant has also placed reliance on the decision of the Coordinate Bench of this Tribunal in the case of Kuruganti Srivalli Vs ACIT Central Circle, Dhanbad in ITA no. 84/Ran/2024 dated 18/12/2025. We have considered the above submissions and it is found that the Assessing Officer has failed to identify and co-relate each and every item of jewellery with the persons residing together. Similarly, the Assessing Officer has also failed to correlate three gold bullions weighing 100 gms each found in the locker No. 87 in Punjab & Sindh bank with individual family members while it was jointly held in the name of Anju Kumari and her father-in-law Kapil Deo Lal, it is found that the gold bullion was already declared in the name of Chandrawati Devi, mother in law of the assessee under VDIS declaration of 1997 which was already accepted by the department. Thus, considering the entire facts and circumstances of the case, we are of the opinion that this is a common practice in all joint families that the jewellery and bullions are kept together either in the residence or in the bank lockers and unless there is an individual item of jewellery is segregated and correlated with the persons, the overall benefit of CBDT Circular No. 1916 dated 11/05/1994 cannot be denied to the assessee which allow 500 gms per lady and 200 gms per male persons. Thus, the addition as made by the Assessing Officer and confirmed by the ld. CIT(A) is deleted on both the counts and the appeal is allowed.

8. In the result, this appeal of the assessee is allowed.

Order pronounced in open court on 30/09/2026.