Section 277 of the I.T. Act will come into play only when
(i) any false statement has been made in any Verification; or
(ii) any account or statement has been delivered, which is found to be false.
When you say that your wife has not filed any income tax return, it is not clear, whether your wife made any false statement in any verification, or delivered any account or statement which is false.
It is also not clear what is alleged in the Sec. 277 Notice. Without knowing this, it will be difficult to give any answer to your query.
In any case, your wife has to respond to the notice, by stating whatever that she wants to say.