The assessee, engaged in wholesale trading of gold ornaments, was intercepted during travel with stock supported by delivery challans. While the GST authorities found no irregularities, the Income Tax Department initiated proceedings under section 132A, seizing 398 pieces of jewellery weighing 4,603.110 grams (gross) and 4,146.69 grams (net). The department noted discrepancies between the jewellery and the stock register, non-furnishing of itemized stock records, and mismatch in valuation, leading to retention of goods. The High Court held that where factual disputes exist regarding itemized stock and quantity, the assessing authority is entitled to verify details during assessment. Non-release of goods pending assessment was justified, and the assessee could seek remedy post-assessment if tax liability arose. Petition dismissed. (AY. 2024-25)