Penalty u/s 271AAB not imposable in absence of specific charge

Sushil Kumar Paul Vs ACIT (ITAT Kolkata) ITAT Kolkata held the levy of penalty under section 271AAB of the Income Tax Act without specifying the charge on which the same is imposable is unsustainable in law. Facts- A search and seizure operation was conducted on the premises of assessee on 28.03.2016 and consequence to that the assessee had disclosed a sum of Rs. 79,00,000/-. Subsequently, the assessee was filed his return of income by showing income of Rs. 83,02,410/- including the said undisclosed income of Rs. 79,00,000/- on 31.01.2017. The ld. AO had accepted the return of income filed by ...