Dismissing the appeal of the revenue the Court held that, Penalty cannot be levied on the ground that the assessee had not substantiated the manner in which the undisclosed income was derived is not sustainable where the assessee in the return of income had included that amount and no addition to the returned income was made by the Assessing Officer. (AY. 2012-13)
PCIT v. Bhavi Chand Jindal (2018) 170 DTR 401 / 305 CTR 180/( 2019) 414 ITR 654 (Delhi )(HC )
S. 271AAA : Penalty-Search initiated on or after 1st June, 2007–Penalty cannot be levied on the ground that the assessee had not substantiated the manner in which the undisclosed income was derived is not sustainable where the assessee in the return of income had included that amount and no addition to the returned income was made by the Assessing Officer. [S. 132(4)]