Penalty U/s. 271AAA lieviable if Conditions precedent not satisfied

Asst. CIT Vs. Shailesh Gopal Mhaske (ITAT Pune)

In cases where the assessee claims the immunity from levy of penalty under section 271AAA of the Act, sub- section (2) provides that three conditions to be fulfilled but in actual fact there are four steps are to be undertaken before grant of any immunity under section 271AAA of the Act, which are as under: —

(a) Assessee in the statement recorded under section 132(4) of the Act admits the undisclosed income;

(b) Assessee satisfies the manner in which the income has been derived;

(c) Assessee substantiate the manner in which the undisclosed income was derived; and

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