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    <title>Penalty under s.271(1)(c) read with s.274 quashed for lack of specific charge, denying fair notice</title>
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    <description>The ITAT held that penalty proceedings under s.271(1)(c) read with s.274 were vitiated where the AO&#039;s notice failed to specify which limb of s.271(1)(c) (concealment of particulars or furnishing of inaccurate particulars/under-reporting or misreporting) was invoked and did not strike out the irrelevant portion of the charge. Applying the controlling full-bench ratio, the Tribunal concluded that procedural infirmity deprived the assessee of fair notice; accordingly the penalty orders framed by the AO under s.271(1)(c) were held invalid and were quashed, with the appeal allowed in favour of the assessee.</description>
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    <pubDate>Tue, 16 Sep 2025 09:02:41 +0530</pubDate>
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      <title>Penalty under s.271(1)(c) read with s.274 quashed for lack of specific charge, denying fair notice</title>
      <link>https://www.taxtmi.com/highlights?id=92560</link>
      <description>The ITAT held that penalty proceedings under s.271(1)(c) read with s.274 were vitiated where the AO&#039;s notice failed to specify which limb of s.271(1)(c) (concealment of particulars or furnishing of inaccurate particulars/under-reporting or misreporting) was invoked and did not strike out the irrelevant portion of the charge. Applying the controlling full-bench ratio, the Tribunal concluded that procedural infirmity deprived the assessee of fair notice; accordingly the penalty orders framed by the AO under s.271(1)(c) were held invalid and were quashed, with the appeal allowed in favour of the assessee.</description>
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      <pubDate>Tue, 16 Sep 2025 09:02:41 +0530</pubDate>
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