Levy of penalty u/s 271(1)(c) - Defective notice u/s 274 -...

Levy of penalty u/s 271(1)(c) - Defective notice u/s 274 - Emphasizing the principles outlined by the Karnataka High Court, the Tribunal reaffirmed the importance of clear and specific grounds for imposing penalties under Section 271(1)(c) of the Act. It clarified that penalties should only be imposed based on the grounds stated in the notice, and the validity of assessment cannot be a subject matter of penalty proceedings. The Tribunal agreed with the appellant's argument against the applicability of Section 292B to cure the defect in the notice under Section 274, reiterating that the notice did not conform to the intent and purpose of the Act.