Net wealth inclusion fails where voluntary disclosure is unsupported by proof of cash or other matching assets.

Amounts disclosed under section 14 of the Voluntary Disclosure Act, 1976 could not be added to net wealth where the declaration form showed income disclosure and tax payment but the asset columns were left blank. In the absence of any independent evidence that the balance amount was represented by cash or other identifiable assets, the department could not support the addition by mere inference that the amount continued to be held by the assessee. The disclosed amount was therefore not part of the assessee's wealth, and the proposed addition was unsustainable.

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Issues: Whether the amount disclosed under section 14 of the Voluntary Disclosure Act, 1976, but not shown to be represented by any asset, could be added to the assessee's net wealth.

Analysis: The declaration in Form B showed disclosure of income and payment of tax, but the relevant columns requiring particulars of assets were left blank. The department produced no independent evidence to establish that the balance amount remained with the assessee in the form of cash or any other asset. In the absence of matching assets on record, the addition could not rest on a mere inference that the amount must have continued to be held by the assessee.

Conclusion: The amount could not be treated as part of the assessee's wealth and the addition was not sustainable.

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