Whether on the facts and in circumstances of thecase, the learned ITAT has erred in law and on fact indeleting the penalty of Rs. 1,00,00,000/- levied u/s. 271AAA of the Act by holding that the condition provided u/s. 271AAA(2) stood satisfied as assessee was not asked to specify the manner in which such income was earned and substantiate the manner in which income was derived, even though as per the provisionit was for the assessee to voluntarily state the above even if no such query was put to the assessee?