Voluntary disclosure is not conclusive in jewellery valuation; registered valuer's report prevails absent contrary proof.

In wealth-tax valuation, an admission in a voluntary disclosure is relevant evidence but not conclusive, because the assessment must first identify the jewellery actually held on the valuation date and then determine its value. Where the declaration disclosed only a value, without particulars of the jewellery or contrary material showing that the assessees held more items than those reflected in the registered valuer's report, the earlier admitted figure could not displace direct expert valuation. Suspicion arising from the disclosure was insufficient to reject the valuation report. The Tribunal therefore accepted the registered valuer's report, set aside the additions, and directed revision of the assessments on that basis.

---

---

Issues: Whether the value of jewellery for the relevant assessment years was to be fixed on the basis of the value admitted in the voluntary disclosure or on the basis of the registered valuer's report.

Analysis: An admission in a voluntary disclosure is relevant and may carry evidentiary weight, but it is not invariably conclusive. Under the scheme of the Wealth-tax Act, the first step is to ascertain the jewellery held on the valuation date and the second is to determine its value. The declaration made by the assessee disclosed only a value and did not furnish particulars or valuation details of the jewellery. In the absence of material showing that the assessee held more items than those reflected in the valuer's report, and in the absence of contrary evidence to displace the expert valuation, the earlier admitted figure could not by itself govern the assessment. The prior declaration could create suspicion, but suspicion was insufficient to reject direct evidence of valuation.

Conclusion: The value of the jewellery had to be taken on the basis of the registered valuer's report, and the assessee's admitted figure in the voluntary disclosure was not binding or conclusive.

Final Conclusion: The additions made by the revenue authorities were set aside and the assessments were directed to be revised on the basis of the lower valuation accepted by the Tribunal.

Ratio Decidendi: An admission in a voluntary disclosure is only relevant evidence and not conclusive where it is shown to be erroneous and is unsupported by material as to the actual assets held; in wealth-tax valuation, direct expert evidence of value prevails in the absence of contrary proof.

---