https://www.taxtmi.com/caselaws?id=787866 Penalty proceedings for concealment of income or furnishing inaccurate particulars require a show-cause notice that clearly specifies the precise limb invoked. Leaving both alternatives unstruck, followed by findings relying on both limbs, creates ambiguity, deprives the assessee of a definite charge and a proper opportunity to defend. Such ambiguity goes to the root of the penalty process. The notice was therefore invalid, the penalty proceedings were quashed, and the appeal succeeded for the assessee. en-us Fri, 13 Feb 2026 00:00:00 +0530 Fri, 13 Mar 2026 08:36:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787866 Penalty proceedings for concealment of income or furnishing inaccurate particulars require a show-cause notice that clearly specifies the precise limb invoked. Leaving both alternatives unstruck, followed by findings relying on both limbs, creates ambiguity, deprives the assessee of a definite charge and a proper opportunity to defend. Such ambiguity goes to the root of the penalty process. The notice was therefore invalid, the penalty proceedings were quashed, and the appeal succeeded for the assessee. Case-Laws Income Tax Fri, 13 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787866