Penalty U/s. 271AAA not leviable on Failure to ask question regarding manner of earning of income

As per section 271AAA(2)(i), one of the conditions for obtaining relief from the imposition of penalty under section 271AAA is that the assessee in the statement recorded under section 132(4) of the Act admits the undisclosed income and ‘specifies the manner’ in which such income has been derived. Section 271AAA(2)(ii) casts obligation on the part of the assessee to ‘substantiate the manner’ in which the undisclosed income was derived. Thus, sub-section (2)(ii) finds its genesis from sub-section 2(i) of the Act. Admittedly, the Revenue is

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