During the search, cash was found, and the assessee voluntarily offered additional income in the return filed under section 153A by estimating disallowance of marketing expenditure. The Tribunal held that the surrendered income was neither linked to any specified previous year nor represented falsification of entries in the books of account as contemplated by Explanation (c) to section 271AAB. The surrender was based on estimation and was not supported by any specific evidence establishing undisclosed income for the relevant assessment year. Consequently, the penalty under section 271AAB was deleted. The Assessing Officer issued a notice under section 274 read with section 271AAB without specifying whether penalty was proposed under clause (a) or clause (b) of section 271AAB(1A). The Tribunal held that section 271AAB contemplates different conditions and rates of penalty under different clauses, and the assessee must be informed of the precise charge. A vague notice reflected complete non-application of mind and violated the principles of natural justice. Accordingly, the penalty order was held to be void ab initio.  (AY. 2019-20).