Allowing the appeal of the assesee the Court held, the declaration had been accepted upon the assessees paying the requisite taxes. The documents filed in support were available before the Assessing Officer and were on record. In fact, the copies of the sale bills of the gold and silver bullion corresponded to the bullion quantities as converted. The mere change in the nomenclature from jewellery to bullion in the Voluntary Disclosure of Income Scheme declaration vis-a-vis sale bills would not be relevant. The Tribunal committed a serious error in arriving at a conclusion that items sold by the respective assessees were different from the jewellery declared under the Voluntary Disclosure of Income Scheme. The addition to income was not justified. (AY. 1998-99)