B. P. JEEVAN REDDY, CJ. ( 1 ) THIS writ petition is directed against an order of the Commissioner of Wealth-tax, Lucknow, made on August 16, 1980, under Section 18b of the Wealth-tax Act, 1957. By the said order, the commissioner has rejected the application made by the petitioner for waiver of penalties imposed in respect of three assessment years. ( 2 ) THE petitioner filed returns under the Wealth-tax Act in respect of the assessment years 1972-73 and 1973-74 on October 7, 1974. For the assessment year 1974-75, however, he had filed the same on September 30, 1974 itself. The assets owned by him included an agricultural property. He valued the same at Rs. 400 per bigha according to which the value of the said asset ranged near about 80,000. The Wealth-tax Officer, however, did not accept the said valuation. He noticed that the income from the said asset disclosed by the petitioner himself was rupees eight to ten thousand per annum. Applying the multiple of fifteen, he valued the said assets at Rs. 1,50,000. On appeal, the valuation was reduced to Rs. 1,08,000 and that became final. On the ground that the petitioner had not filed the returns for the said three assessment years within the time prescribed, proceedings for levy of penalty were taken under Section 18 of the Act and penalties in a sum of Rs. 11,414 for the first year, Rs. 5,759 for the second year and Rs. 433 for the third year were imposed. This order also became final. The petitioner then applied to the commissioner under Section 18b for waiving the said penalties which application has been dismissed under the impugned order. The only reason given for rejecting the said application is that "there is much variation between the returned and assessed wealth for all the relevant assessment years. As such, the disclosure of wealth cannot be treated to be full and true". ( 3 ) SUB-SECTION (1) of Section 18b read as follows : "18b. The only reason given for rejecting the said application is that "there is much variation between the returned and assessed wealth for all the relevant assessment years. As such, the disclosure of wealth cannot be treated to be full and true". ( 3 ) SUB-SECTION (1) of Section 18b read as follows : "18b. Power to reduce or waive penalty in certain cases.-- (1) Notwithstanding anything contained in this Act, the Chief Commissioner or Commissioner may, in his discretion, whether on his own motion or otherwise, -- (i) reduce or waive the amount of penalty imposed or imposable on a person under Clause (i) of sub-section (1) of Section 18 for failure without reasonable cause to furnish the return of net wealth which such person was required to furnish under Sub-section (1) of Section 14 ; (ii) reduce or waive the amount of penalty imposed or imposable on a person under Clause (iii)of Sub-section (1) of Section 18, if he is satisfied that such person,-- (a) in the case referred to in Clause (i), has, prior to the issue of a notice to him under sub-section (2) of Section 14, voluntarily and in good faith, made full and true disclosure of his net wealth, and (b) in the case referred to in Clause (ii), has prior to the detection by the Assessing Officer, of the concealment of particulars of assets or of the inaccuracy of particulars furnished in respect of any asset or debt in respect of which the penalty is imposable, voluntarily and in good faith made full and true disclosure of such particulars, and also has co-operated in any inquiry relating to the assessment of his net wealth and has either paid or made satisfactory arrangements for the payment of any tax or interest payable in consequence of an order passed under this Act in respect of the relevant assessment year. " ( 4 ) THIS is a case falling under Clause (i) and Clause (a), respectively, of Sub-section (1 ). In such a case, the discretion of the Commissioner comes into play on the following ingredients being satisfied : 1. There must be a full and true disclosure of the assessees net wealth in good faith. 2. Such disclosure must have been made voluntarily prior to the issue of notice under Section 14 (2 ). 3. In such a case, the discretion of the Commissioner comes into play on the following ingredients being satisfied : 1. There must be a full and true disclosure of the assessees net wealth in good faith. 2. Such disclosure must have been made voluntarily prior to the issue of notice under Section 14 (2 ). 3. The assessee must have co-operated in any inquiry relating to the assessment of his net wealth. 4. The assessee must have either paid or made satisfactory arrangements for the payment of any tax or interest payable in consequence of an order passed for the said assessment year. ( 5 ) IN this case, the Commissioner says that because there is substantial variation between the returned and assessed wealth, it cannot be said that the assessee has made a full and true disclosure of his net wealth in good faith. The question is whether he is right in the circumstances of the case. ( 6 ) UNDOUBTEDLY, there is variation between the returned and assessed wealth in this case. This was brought about because the valuation of the agricultural asset disclosed by the petitioner was not accepted by the assessing authorities who enhanced the same taking the annual income from the agricultural asset disclosed by the assessee himself, as the basis. ( 7 ) IN Hasan Ahmad Khan v. CWT [1975] 99 ITR 414, a Bench of this court considered a case in identical circumstances. It has been held that the requirement of full and true disclosure in good faith is a single condition and what it means is that the Commissioner has to be satisfied that, while disclosing his net wealth fully, the assessee has acted in good faith. It is held that, if the assessee honestly thought that he has fully disclosed his net wealth, although the disclosure made by him is ultimately found to be inaccurate, it would not be possible to say that he did not act in good faith. The angle from which the matter has to be examined is whether the assessee made a full disclosure of his net wealth or not; it is not to be looked at with reference to the net wealth as ultimately evaluated by the Wealth-tax Officer. In our opinion, the principle of the said decision clearly goes to support the petitioners contention in this case. In our opinion, the principle of the said decision clearly goes to support the petitioners contention in this case. ( 8 ) FOLLOWING the said decision, we allow the writ petition and quash the impugned order. The commissioner of Wealth-tax shall dispose of the application made by the petitioner under section 18b afresh in accordance with law including the principles indicated in the aforesaid bench decision of this court. No costs. .