https://www.taxtmi.com/caselaws?id=754920 The ITAT Mumbai held that penalty orders under section 271(1)(c) are invalid when the AO fails to specify which limb of the provision applies at both initiation and imposition stages. The tribunal emphasized that penalty notices under section 274 read with section 271(1)(c) must contain specific charges rather than general allegations, as ambiguous notices violate mandatory procedural requirements. Following precedent from Mohd. Farhan A. Shaikh, the tribunal ruled that failure to meet mandatory communication requirements renders the penalty proceedings fatal, requiring no further proof of invalidity. The assessee's appeal was allowed. en-us Fri, 28 Jun 2024 00:00:00 +0530 Wed, 03 Jul 2024 08:44:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754920 The ITAT Mumbai held that penalty orders under section 271(1)(c) are invalid when the AO fails to specify which limb of the provision applies at both initiation and imposition stages. The tribunal emphasized that penalty notices under section 274 read with section 271(1)(c) must contain specific charges rather than general allegations, as ambiguous notices violate mandatory procedural requirements. Following precedent from Mohd. Farhan A. Shaikh, the tribunal ruled that failure to meet mandatory communication requirements renders the penalty proceedings fatal, requiring no further proof of invalidity. The assessee's appeal was allowed. Case-Laws Income Tax Fri, 28 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754920