Per Vimal Gandhi - In all these appeals, the assessees have objected to levy of penalty under section 18(1)(c) of Wealth-tax Act for disclosure of low value of jewellery in the returns. The relevant particulars of wealth assessed; value of jewellery shown and assessed in the three cases are as under:

2. The assessees have claimed that the value of jewellery was disclosed on the basis of value shown in the immediately preceding assessment year as the said value was taken to be valid for 3 years as per the instructions of the CBDT. However, in the course of assessment proceedings, the assessee got the jewellery valued and furnished the report of registered valuer to the assessing officer before any discrepancy was detected. There is some dispute on this controversy but after considering relevant record, we are inclined to hold that the