Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Membership-consent thresholds for oppression petitions are satisfied by unchallenged voter-list consents, while unsupported forgery claims require pro...
The penalty notice issued u/s 271(1)(c) of the Act was defective as it did not specify whether the penalty proceedings were initiated for concealment of income or furnishing of inaccurate particulars of income. When the charge is not specified in the notice, it is considered an omnibus notice. The Delhi High Court in the case of PCIT vs. Sahara India Life Insurance Co. Ltd. and the Bombay High Court in the case of Mr. Mohd. Farhan A. Shaikh (Full Bench) held that the penalty order passed without specifying the charge in the notice is liable to be quashed due to this fatal defect. Consequently, the penalty in this case is liable to be deleted in favor of the assessee.
The penalty notice issued u/s 271(1)(c) of the Act was defective as it did not specify whether the penalty proceedings were initiated for concealment of income or furnishing of inaccurate particulars of income. When the charge is not specified in the notice, it is considered an omnibus notice. The Delhi High Court in the case of PCIT vs. Sahara India Life Insurance Co. Ltd. and the Bombay High Court in the case of Mr. Mohd. Farhan A. Shaikh (Full Bench) held that the penalty order passed without specifying the charge in the notice is liable to be quashed due to this fatal defect. Consequently, the penalty in this case is liable to be deleted in favor of the assessee.
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TaxTMI 
TaxTMI 
of 4883 
