Voluntary disclosure valuation binds the declarant, preventing a later lower wealth-tax valuation for the same disclosed asset.

A declarant under the Voluntary Disclosure of Income and Wealth Ordinance, 1975 is bound by the value stated in the declaration for the same disclosed asset. Where jewellery was voluntarily disclosed and tax was paid on that declared value, the assessee could not later insist on a lower valuation in wealth-tax assessment by relying on an earlier valuer's report. Allowing a revised lower figure would defeat the scheme's purpose and could produce an unintended refund. The disclosed valuation therefore remained operative for assessment purposes, while any dispute over the declaration itself would have to be dealt with according to law.

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Issues: Whether an assessee who made a declaration under the Voluntary Disclosure of Income and Wealth Ordinance, 1975 and paid tax on the declared value could, in the subsequent wealth-tax assessment, insist on a lower valuation for the same jewellery on the basis of an earlier valuer's report.

Analysis: The declaration under the voluntary disclosure scheme was made in solemn affirmation and accepted for the purpose of the scheme, conferring immunity from penalty. The Court held that the scheme contemplated declaration and payment of tax on the disclosed wealth, and permitting the declarant thereafter to reduce the declared valuation in the assessment proceedings would frustrate the purpose of the scheme and could even result in an unintended refund. The assessee was therefore bound by the value voluntarily declared in respect of the same asset, and could not reopen that valuation merely by relying on an earlier valuation report. If the declaration itself was disputed, the Wealth-tax Officer could proceed according to law, but the declarant could not both retain the benefit of the scheme and seek a lower valuation for the very asset already disclosed.

Conclusion: The assessee was not entitled to claim a lower valuation of the disclosed jewellery in the assessment proceedings; the reference was answered against the assessee and in favour of the Revenue.

Ratio Decidendi: A declarant under a voluntary disclosure scheme is bound by the valuation stated in the declaration for the same disclosed asset and cannot, while retaining the scheme's benefits, seek reassessment on a lower value in ordinary assessment proceedings.

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