During search, gold and diamond jewellery was seized from lockers jointly held by assessee and her mother-in-law. Additions were made in respective cases on substantive and protective basis. Commissioner (Appeals) held that additions made on presumption in ratio of 50:50 ownership were invalid and recorded categorical findings regarding ownership of jewellery. Consequently, the Assessing Officer passed an appeal effect order whereby addition in respect of unexplained jewellery was quantified in hands of assessee. Thereafter, the assessee filed declaration under the Vivad Se Vishwas Scheme and paid the determined amount of Rs. 72,241 towards full and final settlement of tax liability, and the same was accepted by the competent authority. However, the Assessing Officer did not release seized jewellery on the ground of subsisting demand in case of the mother-in-law, who was a joint holder of the locker. On writ, the court held that since liability of assessee stood determined and culminated by issuance of Form-5, the Assessing Officer had no authority to further detain the seized jewellery of assessee on the pretext of liability of another person. Therefore, continued detention of jewellery after passing of appellate order and issuance of Form-5 was illegal and perverse and directed to be released.