Penalty U/s. 271AAA cannot be levied if not asked to substantiate Income Disclosed

ACIT Vs Sh. Bhavi Chand Jindal (ITAT Delhi) Since no specific query was raised, at the time of recording statement under section 132(4) and during the assessment proceedings, however, the manner was substantiated by filing written submission and also referring relevant documents relating to undisclosed income, which were found and seized. Therefore, assessee was not at fault for substantiating the manner for earning the undisclosed income, in the absence of any specific query raised by AO while recording statement under section 132(4). FULL TEXT OF THE ITAT JUDGMENT This appeal by the Revenue ...