https://www.taxtmi.com/caselaws?id=751657 ITAT Mumbai held that penalty u/s 271(1)(c) cannot be levied when charges are not made specific. The AO made ad hoc 50% disallowance of expenditure without specifying whether assessee concealed income or furnished inaccurate particulars. The penalty notice invoked twin charges without confronting assessee with specific allegations during assessment. ITAT ruled that ad hoc disallowances without specific reasons do not warrant penalty under section 271(1)(c). The penalty order was reversed and AO directed to delete the penalty. Decision favoured assessee. en-us Fri, 19 Apr 2024 00:00:00 +0530 Mon, 22 Apr 2024 14:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751657 ITAT Mumbai held that penalty u/s 271(1)(c) cannot be levied when charges are not made specific. The AO made ad hoc 50% disallowance of expenditure without specifying whether assessee concealed income or furnished inaccurate particulars. The penalty notice invoked twin charges without confronting assessee with specific allegations during assessment. ITAT ruled that ad hoc disallowances without specific reasons do not warrant penalty under section 271(1)(c). The penalty order was reversed and AO directed to delete the penalty. Decision favoured assessee. Case-Laws Income Tax Fri, 19 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751657