https://www.taxtmi.com/caselaws?id=754271 The ITAT Chennai ruled that penalty proceedings under section 271(1)(c) were defective due to the AO's failure to specify exact charges against the assessee. The tribunal held that "concealment of income" and "furnishing inaccurate particulars" are distinct charges requiring specific identification before penalty imposition. The AO cannot leave charge determination to presumption or guesswork. Similarly, "under-reporting" and "misreporting" of income constitute separate charges that must be specifically framed. The tribunal deleted the penalties for all assessment years, citing the defective notice as fatal to proceedings and not curable under section 292BB. en-us Mon, 03 Jun 2024 00:00:00 +0530 Thu, 20 Jun 2024 08:37:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754271 The ITAT Chennai ruled that penalty proceedings under section 271(1)(c) were defective due to the AO's failure to specify exact charges against the assessee. The tribunal held that "concealment of income" and "furnishing inaccurate particulars" are distinct charges requiring specific identification before penalty imposition. The AO cannot leave charge determination to presumption or guesswork. Similarly, "under-reporting" and "misreporting" of income constitute separate charges that must be specifically framed. The tribunal deleted the penalties for all assessment years, citing the defective notice as fatal to proceedings and not curable under section 292BB. Case-Laws Income Tax Mon, 03 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754271