https://www.taxtmi.com/caselaws?id=768042 ITAT Delhi held that penalty u/s 271(1)(c) was unsustainable due to defective notice u/s 274. The AO failed to specify whether proceedings were for concealment of income particulars or furnishing inaccurate particulars, keeping both limbs without striking off irrelevant words. Following SC precedent in Dilip N. Shroff, the tribunal found this demonstrated non-application of mind by the AO, as the two limbs carry different meanings and the assessee must know the specific charge to respond appropriately. The penalty proceedings were deemed unsustainable and the assessee's appeal was allowed. en-us Thu, 27 Mar 2025 00:00:00 +0530 Sat, 29 Mar 2025 08:15:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768042 ITAT Delhi held that penalty u/s 271(1)(c) was unsustainable due to defective notice u/s 274. The AO failed to specify whether proceedings were for concealment of income particulars or furnishing inaccurate particulars, keeping both limbs without striking off irrelevant words. Following SC precedent in Dilip N. Shroff, the tribunal found this demonstrated non-application of mind by the AO, as the two limbs carry different meanings and the assessee must know the specific charge to respond appropriately. The penalty proceedings were deemed unsustainable and the assessee's appeal was allowed. Case-Laws Income Tax Thu, 27 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768042