https://www.taxtmi.com/highlights?id=95128 Validity of penalty under s.271(1)(c) turned on whether the notice specified a clear and consistent charge. Since the show-cause notice proceeded on "furnishing inaccurate particulars" but the penalty order treated the case as involving "both concealment and inaccurate particulars" and ultimately computed and levied penalty on alleged "concealment," there was a fatal variance undermining jurisdiction and violating the requirement that the two limbs are distinct. Consequently, the penalty was quashed and the appeal was allowed. - ITAT en-us Wed, 17 Dec 2025 16:26:37 +0530 Wed, 17 Dec 2025 16:26:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=95128 Validity of penalty under s.271(1)(c) turned on whether the notice specified a clear and consistent charge. Since the show-cause notice proceeded on "furnishing inaccurate particulars" but the penalty order treated the case as involving "both concealment and inaccurate particulars" and ultimately computed and levied penalty on alleged "concealment," there was a fatal variance undermining jurisdiction and violating the requirement that the two limbs are distinct. Consequently, the penalty was quashed and the appeal was allowed. - ITAT Highlights Income Tax Wed, 17 Dec 2025 16:26:37 +0530 https://www.taxtmi.com/highlights?id=95128