Gold jewellery worth Rs 1.65 crore and silver articles weighing 3 kg were seized from the residence of Suresh (name withheld) during an Income Tax Department search in November 2019. The Assessing Officer (AO) added the value to Suresh’s income as unexplained investment under Section 69 of the Income Tax Act, citing discrepancies between invoices, bank and credit card payments, and the inventory prepared during the search. Suresh contended that the jewellery belonged to his wife, Shubha Sunil, whose tax return had already disclosed the same assets. He also claimed that some of the jewellery was ancestral or received as gifts, though he did not provide documentary proof. Dissatisfied with the AO’s addition, Suresh appealed to the Commissioner of Appeals (CIT(A)) and subsequently to the

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