Voluntary disclosure immunity does not bar wealth-tax assessment on true asset value; valuation issue remanded for fresh consideration.

Immunity under a voluntary disclosure scheme applies only to the statutory protection expressly granted, and it does not prevent wealth-tax authorities from examining whether the disclosure was correct or complete. Once regular assessment proceedings begin, the Wealth-tax Officer may determine the true value of assets and assess net wealth on that basis, even if the declaration showed a lower figure. The valuation dispute over immovable properties was not examined on merits by the first appellate authority because the primary disclosure-based contention had been accepted, so the matter was remanded for fresh consideration in accordance with law.

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Issues: (i) Whether a declaration under the Voluntary Disclosure of Income and Wealth scheme barred the wealth-tax authorities from making an assessment on a higher value than that disclosed. (ii) Whether the valuation dispute regarding the immovable properties required fresh consideration on merits by the first appellate authority.

Issue (i): Whether a declaration under the Voluntary Disclosure of Income and Wealth scheme barred the wealth-tax authorities from making an assessment on a higher value than that disclosed.

Analysis: The scheme granted immunity in respect of the amount declared for the specified purposes of penalty or prosecution, but it did not prevent the revenue from examining whether the disclosure was correct and complete. The proceedings under the voluntary disclosure scheme were distinct from regular wealth-tax assessment proceedings. Once regular assessment proceedings were initiated, the Wealth-tax Officer could ascertain the true value of the assets and assess the assessee on the correct net wealth, even if the declaration under the scheme showed a lower figure.

Conclusion: The wealth-tax authorities were entitled to make an assessment on the correct net wealth, and the assessee's disclosure under the scheme did not bind them to accept the declared values.

Issue (ii): Whether the valuation dispute regarding the immovable properties required fresh consideration on merits by the first appellate authority.

Analysis: The first appellate authority had not examined the assessee's alternative contention that the values adopted by the Wealth-tax Officer were excessive and unjustified, because it had accepted the primary contention based on the voluntary disclosure. In the interests of justice, that valuation issue had to be considered on its own merits and in accordance with law.

Conclusion: The matter on valuation was remanded to the first appellate authority for fresh decision on merits.

Final Conclusion: The revenue succeeded on the principal legal issue, but the valuation dispute was sent back for reconsideration, leaving the cross-objections without surviving independent relief.

Ratio Decidendi: Immunity under a voluntary disclosure scheme extends only to the statutory protection expressly provided by it and does not bar the revenue from examining the correctness of the disclosure or from assessing the taxpayer on the true value under the regular assessment law.

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