https://www.taxtmi.com/caselaws?id=467120 Where penalty proceedings under section 270A were commenced without specifying which sub limb of section 270A(2) was relied upon, that defect was held to vitiate the penalty process; as a result the penalty was unsustainable. The analysis emphasises the legislative purpose of identifiable limbs to ensure objectivity and clarity in penalty imposition, gives weight to the assessee's bona fides (admission of receipts, tax payment before filing, mistake attributed to adviser), and endorses coordinate bench precedent applying the limb theory, concluding procedural infirmity and absence of adverse material justify deletion of the penalty. en-us Fri, 21 Feb 2025 00:00:00 +0530 Fri, 06 Mar 2026 20:54:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467120 Where penalty proceedings under section 270A were commenced without specifying which sub limb of section 270A(2) was relied upon, that defect was held to vitiate the penalty process; as a result the penalty was unsustainable. The analysis emphasises the legislative purpose of identifiable limbs to ensure objectivity and clarity in penalty imposition, gives weight to the assessee's bona fides (admission of receipts, tax payment before filing, mistake attributed to adviser), and endorses coordinate bench precedent applying the limb theory, concluding procedural infirmity and absence of adverse material justify deletion of the penalty. Case-Laws Income Tax Fri, 21 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467120