Allowing the appeal of the revenue , the Court held that  where the assessee in the course of search in a statement under sub-section (4) of S. 132 admitted the undisclosed income and specified the manner in which such income had been derived, then the provisions of S. 271AAB were automatically attracted. The provisions of S.271AAB was applicable as a search had been initiated under S.132 and during the course of search the statement of the assessee had been recorded wherein the assessee admitted undisclosed income and specified the manner in which such income had been derived. The penalty notice issued under S. 274 read with S. 271 clearly indicated that the opportunity of being heard was provided to the assessee and that proceedings under S. 271AAB were being initiated and the reply to the show-cause notice in writing on or before the date so as indicated would be considered before any such order is made under S.271AAB. Admittedly, no proceeding under S.271(1)(c) were initiated by the assessing authority during the course of the assessment proceeding under S. 143(3). The penalty proceedings under S. 271AAB were justified and were initiated in accordance with law. Initiation and imposition of penalty after completion of assessment proceedings was not vitiated by law. The order of the Tribunal could not be sustained and was to be set aside and the penalty orders under S. 271AAB passed by the assessing authority, confirmed by the Commissioner (Appeals), were to be affirmed and restored. ( AY.2014 -15)