Penalty u/s 271AAA Not Imposable Without Statement or Query on Undisclosed Income Source During Assessment.

Penalty u/s 271 AAA - source and manner in which the undisclosed income was derived - where no statement u/s 132(2) of the Act is recorded or specific query is made during assessment, for the purpose of Section 271AAA of the Act, then no inference can be drawn that assessee failed to specify the manner in which such income has been derived or substantiates the manner in which the undisclosed income was derived, so as to levy the penalty. - AT .....

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