Pursuant to a search under S. 132, jewellery was seized from Assessee’s residence and bank lockers. Assessee stated that 901 grams belonged to other relative taxpayers, while the balance belonged to Assessee and his wife. Assessment proceedings verified this aspect as correct, while the remaining jewellery was added to Assessee’s income. The other relative taxpayers sought release of 901 grams, while Assessee sought release of 33 seized jewellery items. Pursuant to CBDT Circular dated 16-10-2023, jewellery was revalued at about `1.20 crores and Assessee furnished a bank guarantee of `1.25 crores. The competent authority approved the release of 33 jewellery items against the said bank guarantee, but the Income Tax Dept later insisted on an enhanced bank guarantee, citing a rise in gold prices. On writ, the Punjab & Haryana High Court  held that since delay in release after approval occurred for unexplained administrative reasons attributable to the Income Tax Dept and beyond the timelines prescribed in the CBDT Circular, Assessee and the other petitioners could not be prejudiced by subsequent increase in market value of jewellery. The High Court directed that therefore, 901 grams of jewellery was to be released to the relative taxpayers subject to affidavits regarding ownership / no objection, and 33 jewellery items were also to be released to Assessee against bank guarantee already furnished, subject to required affidavits.