The assessee was  non -resident . The asseee had filed original return . Thereafter revised the return  before receipt of notice u/s 148 of the Act offering the  peak amount  on account of funds lying in the bank accounts  held by JWL and SF with HSBC Bank Zurich. The second revised return was filed showing the additional income . The second revised return was accepted by the Revenue without making any additions . The AO levied penalty of 200% of the  tax sought to be levied on the amount declared subsequent to filing of original return . On appeal the CIT(A) deleted the penalty on the ground that the assessee has suo-moto and voluntarily offered additional income to tax and that income which was offered  for tax by the assessee in the revised return of income was in any case not chargeable to tax in India . On appeal by the Revenue the Tribunal held that there was mistake in calculating the peak in the revised return which was revised once again . The revised return was accepted without making any addition to income offered . Tribunal affirmed the order of CIT(A). On appeal by the Revenue High Court affirmed the order of the Tribunal .Referred   Mak Data (P.) Ltd. v. CIT ( 2013 ) 358 ITR 593 (SC)   (AY. 2007 -08 )