https://www.taxtmi.com/caselaws?id=770334 ITAT Raipur held that penalty proceedings u/s 271(1)(c) are void ab initio when the notice fails to specify which limb of the provision applies. The tribunal ruled that combining both limbs in a single notice violates natural justice principles, as the assessee must know the specific charge to prepare an adequate defense. Without evidence of malafide conduct, the ambiguous notice hampers the assessee's rights. The AO must apply his mind to case facts and clearly specify the applicable limb before issuing penalty notice. The appeal was allowed. en-us Thu, 24 Apr 2025 00:00:00 +0530 Fri, 20 Feb 2026 17:41:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770334 ITAT Raipur held that penalty proceedings u/s 271(1)(c) are void ab initio when the notice fails to specify which limb of the provision applies. The tribunal ruled that combining both limbs in a single notice violates natural justice principles, as the assessee must know the specific charge to prepare an adequate defense. Without evidence of malafide conduct, the ambiguous notice hampers the assessee's rights. The AO must apply his mind to case facts and clearly specify the applicable limb before issuing penalty notice. The appeal was allowed. Case-Laws Income Tax Thu, 24 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770334