The notice u/s. 133(6) was issued on March 8, 2019 and immediately thereafter the assessee had voluntarily deposited the tax with the computation of income in response to the notice on March 25, 2019. The Assessing Officer issued the notice u/s. 148 on March 30, 2019. The assessee on her own after receiving notice u/s. 148 had voluntarily declared the income in her return and paid taxes thereon. The explanation given by the assessee was neither rejected nor held to be mala fide by the Assessing Officer and once the Assessing Officer had failed to take any objection in the matter, the offer from the assessee on her own was a voluntary offer, and this voluntary action of the assessee could not be considered equivalent to providing inaccurate particulars of income or concealing the particulars of income. Therefore, the levy of penalty was not sustainable. (AY .2012-13)