https://www.taxtmi.com/caselaws?id=405280 The Bombay HC held that penalty proceedings under section 271(1)(c) are vitiated when the notice under section 274 fails to specify applicable grounds by not striking off irrelevant portions. The court ruled that omnibus notices suffer from vagueness and demonstrate non-application of mind. Assessment proceedings cannot cure defects in penalty notices as they are distinct proceedings under separate statutory schemes. The court overruled the Kaushalya precedent, emphasizing that penalty proceedings must stand independently and assessees must be informed of specific grounds only through proper statutory notice. Failure to delete inapplicable portions from printed notices constitutes a mandatory procedural violation with fatal consequences. en-us Thu, 11 Mar 2021 00:00:00 +0530 Tue, 13 May 2025 17:29:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=405280 The Bombay HC held that penalty proceedings under section 271(1)(c) are vitiated when the notice under section 274 fails to specify applicable grounds by not striking off irrelevant portions. The court ruled that omnibus notices suffer from vagueness and demonstrate non-application of mind. Assessment proceedings cannot cure defects in penalty notices as they are distinct proceedings under separate statutory schemes. The court overruled the Kaushalya precedent, emphasizing that penalty proceedings must stand independently and assessees must be informed of specific grounds only through proper statutory notice. Failure to delete inapplicable portions from printed notices constitutes a mandatory procedural violation with fatal consequences. Case-Laws Income Tax Thu, 11 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=405280