Penalty u/s 271AAB - disclosure of income in his statement u/s...

Penalty u/s 271AAB - disclosure of income in his statement u/s 132(4) - Unless and until income offered to tax by an assessee comes within the mischief of undisclosed income and that too of the specified previous year it is not open for the AO to invoke provisions of Section 271AAB - if penalty was mandatory and automatic then the right of appeal u/s 246A would not have been provided