What is the current state of the law on blameworthy conduct for failing to disclose an increase in income before the date of the change?

[144] Since D.B.S., various courts have accepted and acted upon the principle that failing to disclose an increase in income is blameworthy conduct justifying variation to the date of the change. “Blameworthy conduct”, as that concept has developed in the cases, does not simply extend to the most egregious cases of deception or intentional evasion, like this case. It may also extend to cases of mere passivity and “taking the path of least resistance” (Colucci v. Colucci at paragraph 41).