Specific misreporting charge in penalty notices is essential; penalty deleted where riot-damage expenditure classification remained debatable.

Penalty for misreporting of income under section 270A requires notices to identify the specific charge under the applicable clause of section 270A(9). Where the notices did not specify any charge for misreporting or suppression, the Revenue lacked authority to impose the penalty. The underlying classification of riot-related damage as capital or revenue expenditure was also debatable. On these grounds, the section 270A penalty was deleted.

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Issues: Whether penalty for misreporting of income could be sustained where the notices did not specify the applicable charge under section 270A(9), and the underlying claim was debatable.

Analysis: The penalty notices issued throughout the proceedings did not identify any specific charge under section 270A(9)(a) to (f). Those clauses constitute the particular charges for misreporting or suppression, and absence of a specified charge deprived the Revenue of authority to impose the penalty. Further, the characterisation of riot-related damage as capital or revenue expenditure was a debatable issue.

Conclusion: The penalty under section 270A was deleted in favour of the assessee.

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