https://www.taxtmi.com/caselaws?id=464949 ITAT Raipur allowed the assessee's appeal and deleted the penalty imposed u/s 271(1)(c) relating to additions for land compensation, rehabilitation expenses, and provision for leave encashment. It held that "concealment of income" and "furnishing inaccurate particulars" are distinct defaults, and the AO must clearly specify the exact charge in the show cause notice u/s 274. As the AO failed to strike off the irrelevant portion and issued ambiguous notices (including a later notice alleging both defaults), there was no proper application of mind and the assessee was not validly put to notice. The penalty, approximately Rs. 77,895.61 lakhs, was therefore held invalid and vacated. en-us Fri, 09 Jun 2023 00:00:00 +0530 Tue, 25 Nov 2025 20:54:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464949 ITAT Raipur allowed the assessee's appeal and deleted the penalty imposed u/s 271(1)(c) relating to additions for land compensation, rehabilitation expenses, and provision for leave encashment. It held that "concealment of income" and "furnishing inaccurate particulars" are distinct defaults, and the AO must clearly specify the exact charge in the show cause notice u/s 274. As the AO failed to strike off the irrelevant portion and issued ambiguous notices (including a later notice alleging both defaults), there was no proper application of mind and the assessee was not validly put to notice. The penalty, approximately Rs. 77,895.61 lakhs, was therefore held invalid and vacated. Case-Laws Income Tax Fri, 09 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464949