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TMI Blog1991 (2) TMI 58X X X X Extracts X X X X X X X X Extracts X X X X ..... t of the assessment years 1972-73 and 1973-74 on October 7, 1974. For the assessment year 1974-75, however, he had filed the same on September 30, 1974 itself. The assets owned by him included an agricultural property. He valued the same at Rs. 400 per bigha according to which the value of the said asset ranged near about 80,000. The Wealth-tax Officer, however, did not accept the said valuation. He noticed that the income from the said asset disclosed by the petitioner himself was rupees eight to ten thousand per annum. Applying the multiple of fifteen, he valued the said assets at Rs. 1,50,000. On appeal, the valuation was reduced to Rs. 1,08,000 and that became final. On the ground that the petitioner had not filed the returns for the sa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ection (2) of section 14, voluntarily and in good faith, made full and true disclosure of his net wealth, and (b) in the case referred to in clause (ii), has prior to the detection by the Assessing Officer, of the concealment of particulars of assets or of the inaccuracy of particulars furnished in respect of any asset or debt in respect of which the penalty is imposable, voluntarily and in good faith made full and true disclosure of such particulars, and also has co-operated in any inquiry relating to the assessment of his net wealth and has either paid or made satisfactory arrangements for the payment of any tax or interest payable in consequence of an order passed under this Act in respect of the relevant assessment year." This is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ue disclosure in good faith is a single condition and what it means is that the Commissioner has to be satisfied that, while disclosing his net wealth fully, the assessee has acted in good faith. It is held that, if the assessee honestly thought that he has fully disclosed his net wealth, although the disclosure made by him is ultimately found to be inaccurate, it would not be possible to say that he did not act in good faith. The angle from which the matter has to be examined is whether the assessee made a full disclosure of his net wealth or not ; it is not to be looked at with reference to the net wealth as ultimately evaluated by the Wealth-tax Officer. In our opinion, the principle of the said decision clearly goes to support the petit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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