Penalty levied u/s 271AAB - Undisclosed income - Assessee has...

Penalty levied u/s 271AAB - Undisclosed income - Assessee has neither made any surrender of any undisclosed income during the search action nor the penalty has been initiated on the basis of undisclosed income found during such search action. In view of the above factual position, the impugned order of the AO imposing the penalty on the assessee under section 271AAB of the Act does not pass the mandate of the provisions of section 271AAB of the Act - No penalty - AT