Penalty u/s 271AAB(1)(a) - Charge of tax u/s. 115BBE - once the...

Penalty u/s 271AAB(1)(a) - Charge of tax u/s. 115BBE - once the ld. AO has already decided based on the fact that this is the case of search addition and amount declared u/s. 132(4) accepted by the assessee and offered the same in the return of income filed the same will be in accordance with the penal provision of section 271AAB and invoking to provision of section 115BBE in this case is not in accordance with the law and is also against principles of nature justice as no such issue is raised, discussed and confronted with the assessee. - AT