( 1 ) THE assessment years involved are 1964-65 to 1969-70. In all these years, the net wealth returned by the assessee was less than 75 per cent. of the net wealth assessed by the WTO. The WTO initiated penalty proceedings and referred the same to the IAC of Wealth-tax as the minimum penalty imposable exceeded Rs. 1,000 in each of these years under consideration. In response to the show-cause notice, it was pleaded that there was no concealment of any assets on the part of tbe assessee and that the provisions of Section 18 (1) (c) of the W. T. Act, 1957, were not applicable. Reliance was placed on the decision of the Supreme Court in the case of CIT v. Anwar Ali and on some other cases in support of the assessee's contention. It was urged that, in the facts and circumstances of the case, no penalty could be imposed. The IAC observed that the assessee had valued the immovable property at their cost price and not on the market price on the valuation dates. She, therefore, invoked the provisions of Expln. (1) appended to Section 18 (1) (c) as the net wealth returned fell short of 75 per cent. of the net wealth assessed and held that the assessee had failed to