Section 271AAA of the Income Tax Act, 1961 — Penalty — It was incumbent upon the AO to first establish that there was undisclosed  income within the meaning of section 271AAA before any penalty under the section could be levied.  While levying the penalty, the AO had nowhere mentioned specifically any undisclosed income within the meaning of undisclosed income given under section 271AAA, the AO had levied the penalty mechanically by taking difference in the return of income and assessed income. the penalty order was devoid of any specific finding in respect of any specific seized material or undisclosed income detected as a result of Search — Deputy Commissioner of income tax vs. Himanshu Verma [2019] 76 ITR (trib) 698 (Delhi)