TaxTMI 
TaxTMI 
1987 (8) TMI 153
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.... and ultimately the net wealth assessed was Rs. 11,83,970 and Rs. 11,53,420. The contention of the Departmental Representative was that in the penalty proceeding the assessee had submitted that the return was filed on estimate basis and that the valuation report had not been received till the filing of the return and as the assessee had given full particulars in respect of the asset as well as its value and mere enhancement of the value does not lead to the conclusion that there was a concealment. The WTO applied Expln. 4 to s. 18(1)(c) which provides that in case the value of any asset is less than 70 per cent of the value of such asset determined in the assessment then a deemed concealment comes into operation in respect of the asset and ....
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....was given, a further opportunity was afforded to the assessee on 16th March, 1983 in response to which the assessee's counsel has contended as under: "1. That the assessee's wealth is more than 75 per cent is due to the valuation done by the departmental valuer on the high value which has got no basis for concealment in such circumstances; 2. That the assessee filed the return on estimate basis at the time of assessment it was told to the assessing authority that the value be taken as per the valuation report and the return be accordingly treated as revised; 3. That in past years also, no action was, therefore taken-dropped on this ground; 4. That no concealment was, therefore, done. Correct particulars were given in the return, and 5.....