Held  that the year-wise income reported by the assessee and her husband signifying their capacity and high status showed that the assessee and her family members were high net worth individuals and having regard to their high status, holding such jewellery found in the custody of members of their families could not be seen to be abnormal and consequently unexplained. Paragraph 3 of the Central Board of Direct Taxes Instruction No. 1916, dated May 11, 1994 provided that the status of the family and customs and practices of the community to which the family belongs, permit an assessee to hold larger quantity of jewellery and ornaments out of the purview of seizure. The Department recognised the holding of high quantity of jewellery as explained where the assessee was in the high Income-tax brackets. The assessee had thus sufficiently demonstrated the plausibility for holding gold ornaments in excess of the limit prescribed by the instruction. The explanation offered by the assessee that credit should be given for gold, jewellery and ornaments held in the custody of the assessee on behalf of the sister-in-law was tenable. Keeping in mind the overall status of the family as demonstrable from the facts of records, the whole of the gold ornaments found at the time of search required to be treated as clearly explained.  The addition is deleted. (AY.2021-22)