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The ITAT held that the penalty u/s 271AAB could not be levied due to a defective notice. The AO failed to specify the specific limb for initiating penalty proceedings, denying the assessee a reasonable opportunity for an effective reply. As the notice was vague without indicating relevant portions, the Tribunal rightly observed that the penalty could not be levied based on such a defective notice, especially when the assessee had consistently raised the jurisdictional issue. The decision was in favor of the assessee.
The ITAT held that the penalty u/s 271AAB could not be levied due to a defective notice. The AO failed to specify the specific limb for initiating penalty proceedings, denying the assessee a reasonable opportunity for an effective reply. As the notice was vague without indicating relevant portions, the Tribunal rightly observed that the penalty could not be levied based on such a defective notice, especially when the assessee had consistently raised the jurisdictional issue. The decision was in favor of the assessee.
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