https://www.taxtmi.com/caselaws?id=466843 A penalty proceeding premised on a show cause notice must invoke the correct statutory provision and identify the specific alternative limb relied upon when a provision contains disjunctive limbs. Here, proceedings originally contemplated under Section 271AAA were converted into a penalty under Section 271(1)(c) but the notice queried both concealment and inaccurate particulars without specifying which limb was alleged, causing prejudice to the recipient. For that reason the penalty was held unsustainable and set aside: lack of specification of the particular limb and change in the statutory basis rendered initiation and continuation of penalty proceedings defective. en-us Mon, 24 Feb 2025 00:00:00 +0530 Sun, 22 Feb 2026 22:48:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466843 A penalty proceeding premised on a show cause notice must invoke the correct statutory provision and identify the specific alternative limb relied upon when a provision contains disjunctive limbs. Here, proceedings originally contemplated under Section 271AAA were converted into a penalty under Section 271(1)(c) but the notice queried both concealment and inaccurate particulars without specifying which limb was alleged, causing prejudice to the recipient. For that reason the penalty was held unsustainable and set aside: lack of specification of the particular limb and change in the statutory basis rendered initiation and continuation of penalty proceedings defective. Case-Laws Income Tax Mon, 24 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466843