https://www.taxtmi.com/caselaws?id=766058 Penalty proceedings under section 271(1)(c) of the Income-tax Act could not be sustained where the section 274 notice was issued in a pre-printed omnibus format without striking off irrelevant portions and the assessment order did not record a definite satisfaction on the exact limb invoked. The notice failed to specify whether the proposed penalty was for concealment of income, furnishing inaccurate particulars, or both, leaving the basis of initiation ambiguous. On this defect in charge and recorded satisfaction, the penalty notice and consequential proceedings were held invalid, and the penalty orders for all assessment years were set aside. en-us Wed, 12 Feb 2025 00:00:00 +0530 Mon, 17 Feb 2025 08:48:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766058 Penalty proceedings under section 271(1)(c) of the Income-tax Act could not be sustained where the section 274 notice was issued in a pre-printed omnibus format without striking off irrelevant portions and the assessment order did not record a definite satisfaction on the exact limb invoked. The notice failed to specify whether the proposed penalty was for concealment of income, furnishing inaccurate particulars, or both, leaving the basis of initiation ambiguous. On this defect in charge and recorded satisfaction, the penalty notice and consequential proceedings were held invalid, and the penalty orders for all assessment years were set aside. Case-Laws Income Tax Wed, 12 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766058