https://www.taxtmi.com/caselaws?id=783504 ITAT Delhi-AT allowed the assessee's appeal and deleted penalty imposed u/s 271(1)(c). The AO's notice proposed penalty only for "furnishing inaccurate particulars of income," but the penalty order proceeded on both "concealment of income" and "furnishing inaccurate particulars," and computed penalty with reference to alleged concealment. ITAT held that "concealment" and "furnishing inaccurate particulars" are distinct charges and the mismatch between the show cause notice and the penalty actually levied vitiated the assumption of jurisdiction. The incoherence in charge and calculation was held fatal to the penalty. en-us Fri, 12 Dec 2025 00:00:00 +0530 Wed, 17 Dec 2025 08:28:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783504 ITAT Delhi-AT allowed the assessee's appeal and deleted penalty imposed u/s 271(1)(c). The AO's notice proposed penalty only for "furnishing inaccurate particulars of income," but the penalty order proceeded on both "concealment of income" and "furnishing inaccurate particulars," and computed penalty with reference to alleged concealment. ITAT held that "concealment" and "furnishing inaccurate particulars" are distinct charges and the mismatch between the show cause notice and the penalty actually levied vitiated the assumption of jurisdiction. The incoherence in charge and calculation was held fatal to the penalty. Case-Laws Income Tax Fri, 12 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783504