1998 (9) TMI 121

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.... was completed on Rs. 23,94,620. The following additions to the net wealth were sustained in appeal:-   (i) Enhancement in the value of jewellery to the tune of Rs. 13,15,355 as against Rs. 1,84,070 shown by the assessee;   (ii) Disallowance of liability in respect of loan taken from bank against the security of fixed deposit - Rs. 1,12,385.   3. Shri Salil Aggarwal, learned counsel for the assessee appeared before us. It was contended that the jewellery was valued by an approved valuer. Reference was made to the clarification given by the C.B.D.T. in this regard. In view of that clarification, it was contended that no penalty can be levied if the value declared by the assessee is in accordance with the valuation done b....

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....ality of appreciation to that extent, within a span of few months. Price cannot jump from Rs. 63,875 to Rs. 11,95,100 within eleven months under the normal circumstances. Definitely, there appears to be some subterfuge resorted to by the assessee to avail the tax benefit. It is the obligation of every citizen to pay the taxes honestly without resorting to subterfuges. There is behind Taxation Laws as much moral sanction as is behind any other welfare legislation. We recollect the of quoted dictum of Lord Green, MR :- "It scarcely lies in the mouth of the taxpayer who plays with fire to complain of burnt fingers." The matter needs to be decided on the conspectus of factual details. We find that in the order of the Tribunal cited before us ....