A search was carried out at business premises of assesse, during search Managing Director was expressed his inability to reconcile discrepancies in stock. In order to buy peace of mind and to avoid litigation, certain amount was declared as undisclosed income. The AO added amount so declared to as taxable income and passed a penalty order u/s.271AAA. The CIT(A) set aside penalty.

Tribunal  held that, to avail benefit of S. 271AAA(2), assessee has to specify and substantiate manner in which income has been derived in its statement recorded u/s.132(4) and not thereafter. Since Assessee showed inability to reconcile discrepancy in stock and failed to substantiate manner, hence it was not eligible to get general amnesty u/s. 271AAA(2) of the Act .( AY.2010-11)