Section 271AAB penalty cannot be levied if no search U/s. 132

Ashok B Sureban Vs ACIT (ITAT Bangalore) AO levied penalty u/s. 271AAB of the Act on account of undisclosed income declared by the assessee during the post-survey proceedings on 6.8.2015. Against this, the assessee went in appeal before the CIT(Appeals). The CIT(Appeals) confirmed the levy of the penalty u/s. 271AAB of the Act. Aggrieved, the assessee is in appeal before  ITAT. At the outset the ld.AR argued reiterating the grounds of appeal that revenue authorities are not justified in imposing penalty on the assessee u/s. 271AAB of the Act since there was no search in the case of assessee u...