Specific and unambiguous charges are required in penalty...

Specific and unambiguous charges are required in penalty proceedings under section 271(1)(c). The note explains that a penalty notice must clearly identify whether the allegation concerns concealment of income or furnishing inaccurate particulars; an Assessing Officer cannot initiate proceedings on one limb and impose penalty on the other. Where the notice lacks a definite charge or the penalty order changes the stated basis, the notice and consequential penalty are unsustainable. On the facts described, the penalty order was quashed and the merits of the penalty were not examined.

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