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of <h1>Appeals Dismissed: Penalty Notices Lacked Specificity Under Income Tax Act, No Substantial Legal Question Found.</h1> <h3>PR COMMISSIONER OF INCOME TAX DELHI (CENTRAL-3) Versus SHYAM SUNDER JINDAL</h3> PR COMMISSIONER OF INCOME TAX DELHI (CENTRAL-3) Versus SHYAM SUNDER JINDAL - [2024] 462 ITR 501 (Del) Issues:The judgment concerns appeals related to Assessment Years AY 2011-12, AY 2008-09, AY 2010-11, and AY 2009-10 challenging the order passed by the Income Tax Appellate Tribunal.AY 2011-12 (ITA 189/2023):The penalty notices issued did not specify the limb of Section 271(1)(c) of the Income Tax Act, 1961, triggered against the assessee. The appellant's challenge is dismissed based on precedents like Pr. Commissioner of Income Tax-3 v. Ms Minu Bakshi.AY 2008-09 (ITA 190/2023), AY 2010-11 (ITA 191/2023), AY 2009-10 (ITA 192/2023):Similar to AY 2011-12, the penalty notices did not specify the limb of Section 271(1)(c) under which the penalty was sought to be levied. The judgment refers to the necessity for the Assessing Officer to clearly indicate the limb of the provision attracted for penalty proceedings, as highlighted in PCIT v. Unitech Reliable Projects Ltd. case. The court emphasizes that the AO must specify the provision/limb under which penalty proceedings are initiated against the assessee to determine the pecuniary burden accurately.The appeals are not admitted as no substantial question of law arises for consideration, and accordingly, the appeals are closed.
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