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The ITAT held that penalty proceedings under section 271(1)(c) read with section 274 were vitiated because the show-cause notice failed to specify which limb of section 271(1)(c) was invoked, having referenced multiple charges at different stages without striking out inapplicable limbs. The Tribunal followed binding High Court and Supreme Court precedents rejecting notices in a standard format that do not clearly communicate the specific charge sought to be imposed. Consequentially, the penalty assessment was set aside as invalid for defective notice; any further penalty action must be preceded by a valid, specific notice compliant with the requirements of section 274 and relevant judicial decisions.
The ITAT held that penalty proceedings under section 271(1)(c) read with section 274 were vitiated because the show-cause notice failed to specify which limb of section 271(1)(c) was invoked, having referenced multiple charges at different stages without striking out inapplicable limbs. The Tribunal followed binding High Court and Supreme Court precedents rejecting notices in a standard format that do not clearly communicate the specific charge sought to be imposed. Consequentially, the penalty assessment was set aside as invalid for defective notice; any further penalty action must be preceded by a valid, specific notice compliant with the requirements of section 274 and relevant judicial decisions.
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