For quite a long time , the provision of search under Income Tax Act was as if continuous VDIS type of scheme is embedded in the Income Tax Act itself. Why ? Up to 01/06/2007 , Explanation 5 to sec. 271(1)(c) gave the relief to persons disclosing the concealed income in statement recorded u/s 132(4), and accordingly filing tax and return.From 01/06/2007 to 01/07/2012 – the tax evaders will be very happy to get searched ! Why ? There was no penalty on undisclosed income offered u/s 132(4) and tax rate on such undisclosed income was just normal rate of tax .