https://www.taxtmi.com/caselaws?id=753813 ITAT Delhi held that penalty u/s 271(1)(c) imposed on assessee for TP adjustment was unsustainable due to defective notice. The AO made net addition after determining arm's length OP/OC at 13.87%. However, the penalty notice failed to specify which limb of section 271(1)(c) was invoked, merely stating assessee should show cause for concealing income particulars or furnishing inaccurate particulars. Following SC precedents in Reliance Petro Products and SSA's Emerald Meadows, ITAT ruled such ambiguous notices are legally unsustainable, requiring categorical communication of specific limb invoked. Penalty order deleted in assessee's favour. en-us Fri, 31 May 2024 00:00:00 +0530 Mon, 10 Jun 2024 16:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753813 ITAT Delhi held that penalty u/s 271(1)(c) imposed on assessee for TP adjustment was unsustainable due to defective notice. The AO made net addition after determining arm's length OP/OC at 13.87%. However, the penalty notice failed to specify which limb of section 271(1)(c) was invoked, merely stating assessee should show cause for concealing income particulars or furnishing inaccurate particulars. Following SC precedents in Reliance Petro Products and SSA's Emerald Meadows, ITAT ruled such ambiguous notices are legally unsustainable, requiring categorical communication of specific limb invoked. Penalty order deleted in assessee's favour. Case-Laws Income Tax Fri, 31 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753813