1985 (3) TMI 34

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.... also of his wealth in pursuance of the Voluntary Disclosure of Income and Wealth Ordinance, 1975 (Ordinance No. 15 of 1975) (hereinafter referred to as " the Ordinance "). The Wealth-tax Officer, however, initiated proceedings against the assessee for imposition of penalty and passed separate orders imposing penalty on the petitioner in respect of the aforesaid assessment years. Against these orders, the assessee preferred appeals before the Appellate Assistant Commissioner. These appeals were, however, dismissed by a consolidated order dated January 12, 1981. The matter was taken up by the assessee in further appeals before the Income-tax Appellate Tribunal, Allahabad (Bench B). Those appeals were allowed by the Tribunal by its order date....

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....in upholding the imposition of penalty by the Wealth-tax Officer. We find it difficult to agree with this submission. Section 15 of the Ordinance is the relevant section which deals with voluntary disclosure of wealth. It does not contemplate the acceptance by a specific order of the voluntary disclosure made by the assessee. The requirement of the said section which is relevant for the disposal of these applications was that voluntary disclosure could be made on or after the date of commencement of the Ordinance but before the first day of January, 1976, by any person and that such disclosure had to be in the form of declaration in respect of (a) the net wealth chargeable to wealth-tax for any assessment year for which he has failed to fur....