https://www.taxtmi.com/caselaws?id=787620 A challenge concerned whether a penalty under Section 271(1)(c) could stand where the initiating notice under Section 274 read with Section 271(1)(c) failed to state whether it was for concealment of particulars of income or for furnishing inaccurate particulars. The tribunal held that the two limbs have distinct meanings, the assessee must be informed which limb is invoked to enable effective response, and a proforma notice showing no application of mind is defective; accordingly the penalty was held unsustainable and deleted in favour of the assessee. en-us Fri, 06 Mar 2026 00:00:00 +0530 Sat, 07 Mar 2026 12:52:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787620 A challenge concerned whether a penalty under Section 271(1)(c) could stand where the initiating notice under Section 274 read with Section 271(1)(c) failed to state whether it was for concealment of particulars of income or for furnishing inaccurate particulars. The tribunal held that the two limbs have distinct meanings, the assessee must be informed which limb is invoked to enable effective response, and a proforma notice showing no application of mind is defective; accordingly the penalty was held unsustainable and deleted in favour of the assessee. Case-Laws Income Tax Fri, 06 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787620