Penalty under Section 271(1)(c) notice defects and unclear charge; delayed SLP dismissed after condonation refused

Penalty notices under Section 271(1)(c) were defective for failing to specify which limb (concealment or furnishing inaccurate particulars) attracted penalty; Revenue conceded the notices did not state a clear charge. The tribunal issue focused on procedural invalidity of the notices and a separate procedural issue of an inordinate 371 day delay in filing a Special Leave Petition. The Supreme Court recorded refiling and prior orders but ultimately refused condonation of delay and dismissed the application for condonation, with the Special Leave Petition consequently dismissed.

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The Supreme Court, in a judgement by Hon'ble Mrs. Justice B. V. Nagarathna and Hon'ble Mr. Justice Satish Chandra Sharma, noted a gross delay of 371 days in filing a Special Leave Petition. The delay in refiling was condoned. Referring to previous orders in similar cases, the Court dismissed the application seeking condonation of delay, leading to the dismissal of the Special Leave Petition. Any pending applications were disposed of accordingly.

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