No section 271AAA penalty if assessee offered undisclosed income in section 132(4) statement

Late Sh. Krishan Kumar Modi Vs ACIT (ITAT Delhi) ITAT held that penalty under section 271AAA(1) cannot be imposed in a case where the assessee has offered the undisclosed income in the statement recorded under section 132(4) of the Act, specifying the manner in which such income has been derived and if the assessee pays the tax along with interest of such income. In the facts of the present case, undisputedly, the assessee has offered the cash found as income in the statement recorded under section 132(4) of the Act. It is also a fact that the assessee has paid the tax on such income. The only...