https://www.taxtmi.com/caselaws?id=466564 A statutory notice alleging contravention of a multi limbed penal provision must identify which limb is relied upon to enable a focused response; failure to specify whether the charge is concealment of income or furnishing inaccurate particulars deprived the assessee of fair opportunity to defend and caused prejudice. The notice under section 274 that referenced both limbs without particularising was materially defective, and that defect invalidated the ensuing penalty proceedings; accordingly the penalty order under section 271(1)(c) and the appellate order confirming it were set aside in favour of the assessee. en-us Wed, 26 Feb 2025 00:00:00 +0530 Thu, 12 Feb 2026 19:01:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466564 A statutory notice alleging contravention of a multi limbed penal provision must identify which limb is relied upon to enable a focused response; failure to specify whether the charge is concealment of income or furnishing inaccurate particulars deprived the assessee of fair opportunity to defend and caused prejudice. The notice under section 274 that referenced both limbs without particularising was materially defective, and that defect invalidated the ensuing penalty proceedings; accordingly the penalty order under section 271(1)(c) and the appellate order confirming it were set aside in favour of the assessee. Case-Laws Income Tax Wed, 26 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466564