https://www.taxtmi.com/caselaws?id=448302 The HC held that the alleged defect in the penalty notice u/s 271(1)(c) r.w.s. 274, raised after 30 years without any prior objection or demonstrated prejudice, did not amount to a breach of natural justice. The Assessing Officer had considered both limbs of Section 271(1)(c), and the assessee had contested the penalty on that basis. The Court applied settled principles that a technical defect in notice, without real prejudice, does not invalidate proceedings. The delay in raising the issue indicated a belated, technical plea. Reliance on Ventura Textiles Ltd. was rejected, as that case did not apply given the facts. The Court concluded that since no prejudice was shown and the assessee understood the notice's purpose, the penalty proceedings were valid and the matter should proceed before the regular Court. en-us Thu, 11 Jan 2024 00:00:00 +0530 Tue, 12 Aug 2025 18:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448302 The HC held that the alleged defect in the penalty notice u/s 271(1)(c) r.w.s. 274, raised after 30 years without any prior objection or demonstrated prejudice, did not amount to a breach of natural justice. The Assessing Officer had considered both limbs of Section 271(1)(c), and the assessee had contested the penalty on that basis. The Court applied settled principles that a technical defect in notice, without real prejudice, does not invalidate proceedings. The delay in raising the issue indicated a belated, technical plea. Reliance on Ventura Textiles Ltd. was rejected, as that case did not apply given the facts. The Court concluded that since no prejudice was shown and the assessee understood the notice's purpose, the penalty proceedings were valid and the matter should proceed before the regular Court. Case-Laws Income Tax Thu, 11 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448302