https://thetaxtalk.com/2019/02/no-penalty-u-s-271aaa-if-revenue-itself-failed-to-question-in-statement-u-s-132-4-the-manner-of-deriving-such-income/
No Penalty u/s 271AAA if Revenue itself failed to question in statement u/s 132 (4) the manner of deriving such income