https://www.taxtmi.com/caselaws?id=766844 A penalty notice under section 274 read with section 271(1)(c) of the Income-tax Act must clearly specify whether the proposed penalty is for concealment of income or for furnishing inaccurate particulars. An omnibus or vague notice that does not strike off the inapplicable limb fails to convey the precise charge and is substantively defective. The defect was held not curable under section 292B because the notice itself did not satisfy the statutory requirement in substance. The penalty proceedings were therefore unsustainable, with ambiguity operating in favour of the assessee. en-us Thu, 27 Feb 2025 00:00:00 +0530 Wed, 05 Mar 2025 07:49:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766844 A penalty notice under section 274 read with section 271(1)(c) of the Income-tax Act must clearly specify whether the proposed penalty is for concealment of income or for furnishing inaccurate particulars. An omnibus or vague notice that does not strike off the inapplicable limb fails to convey the precise charge and is substantively defective. The defect was held not curable under section 292B because the notice itself did not satisfy the statutory requirement in substance. The penalty proceedings were therefore unsustainable, with ambiguity operating in favour of the assessee. Case-Laws Income Tax Thu, 27 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766844