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Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Penalty u/s. 271(1)(c) - validity of show cause notice issued - The ITAT emphasized the legal necessity for the AO to clearly specify the nature of the default—whether it was for "concealment of particulars of income" or "furnishing of inaccurate particulars." The Tribunal observed that the AO's failure to specify the charge in the Show Cause Notice (SCN) contradicted the principle of providing the assessee with a clear and fair opportunity to defend themselves. The Tribunal allowed the assessee's appeal, setting aside the CIT(A)'s order and the penalty.
Penalty u/s. 271(1)(c) - validity of show cause notice issued - The ITAT emphasized the legal necessity for the AO to clearly specify the nature of the default—whether it was for "concealment of particulars of income" or "furnishing of inaccurate particulars." The Tribunal observed that the AO's failure to specify the charge in the Show Cause Notice (SCN) contradicted the principle of providing the assessee with a clear and fair opportunity to defend themselves. The Tribunal allowed the assessee's appeal, setting aside the CIT(A)'s order and the penalty.
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TaxTMI 
