Specific penalty charge in the statutory notice is mandatory; a vague notice invalidates concealment or inaccurate-particulars penalty proceedings.

A notice under Section 274 for penalty under Section 271(1)(c) must specify the precise charge-concealment of income particulars or furnishing inaccurate particulars-by deleting the inapplicable alternative. Retaining both limbs makes the notice vague, denies a specific opportunity to respond, and breaches principles of natural justice. The stated analysis treats this defect as substantive, invalidating the penalty proceedings from their inception. Accordingly, the discussed notice was treated as invalid, the consequential penalty proceedings were quashed, and the penalty was deleted.

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Issues: Whether penalty proceedings under Section 271(1)(c) were invalid because the notice under Section 274 failed to specify the applicable charge by striking off the inapplicable limb.

Analysis: A penalty notice under Section 274 must clearly identify whether the alleged default is concealment of particulars of income or furnishing of inaccurate particulars of income. A notice retaining both alternatives without striking off the inapplicable charge is vague and violates the requirement of a specific opportunity to respond, offending principles of natural justice. The defect is substantive and invalidates the penalty proceedings at their inception.

Conclusion: The notice under Section 274 was invalid and the consequential penalty proceedings under Section 271(1)(c) were quashed. The penalty was deleted.

Ratio Decidendi: A penalty proceeding under Section 271(1)(c) cannot be sustained where the notice under Section 274 fails to specify the precise charge against the assessee.

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