Held that as per S.  69A, the value of unexplained jewellery shall be deemed to be the income of that financial year in which the assessee is found to be the owner. The express terms of the charging provisions contained in S. 3 and 4 the subject of charge is the income of the ‘previous year’. Each ‘previous year’ is a distinct unit of time for the purposes of assessment and the profits made or the liabilities or losses incurred before or after the previous year is immaterial in assessing the income in a particular previous year. Having regard to the express language used in S. 69A, AO can legally bring to tax unexplained jewellery in the hands of the assessee in that financial year in which the assessee is found to be the owner. Addition as undisclosed is deleted.   (AY. 2013-14)