https://www.taxtmi.com/caselaws?id=420620 Penalty notices under section 274 read with section 271(1)(c) were held invalid because they did not strike off the inapplicable limb and failed to specify whether the allegation was concealment of income or furnishing inaccurate particulars. The vague, omnibus notice was treated as non-application of mind and, applying strict construction of penal provisions, ambiguity was resolved in favour of the assessee. Delay in filing the cross objections was condoned for sufficient cause under section 253(5), and the cross objections were entertained and allowed. Once the penalty was set aside, the revenue appeals did not survive. en-us Thu, 31 Mar 2022 00:00:00 +0530 Wed, 06 Apr 2022 09:09:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=420620 Penalty notices under section 274 read with section 271(1)(c) were held invalid because they did not strike off the inapplicable limb and failed to specify whether the allegation was concealment of income or furnishing inaccurate particulars. The vague, omnibus notice was treated as non-application of mind and, applying strict construction of penal provisions, ambiguity was resolved in favour of the assessee. Delay in filing the cross objections was condoned for sufficient cause under section 253(5), and the cross objections were entertained and allowed. Once the penalty was set aside, the revenue appeals did not survive. Case-Laws Income Tax Thu, 31 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=420620