https://www.taxtmi.com/caselaws?id=467304 A penalty under section 271(1)(c) cannot stand where the initiating notice under section 274 fails to specify which limb-concealment of particulars of income or furnishing inaccurate particulars-is relied upon; the article applies the principle that a show cause notice must be clear and unambiguous to afford the assessee a fair opportunity of defence, and holds that ambiguity vitiates the penalty proceedings. Applying that principle to the facts, the penalty order was quashed and the appeal allowed in favour of the assessee. en-us Mon, 27 Oct 2025 00:00:00 +0530 Fri, 13 Mar 2026 18:58:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467304 A penalty under section 271(1)(c) cannot stand where the initiating notice under section 274 fails to specify which limb-concealment of particulars of income or furnishing inaccurate particulars-is relied upon; the article applies the principle that a show cause notice must be clear and unambiguous to afford the assessee a fair opportunity of defence, and holds that ambiguity vitiates the penalty proceedings. Applying that principle to the facts, the penalty order was quashed and the appeal allowed in favour of the assessee. Case-Laws Income Tax Mon, 27 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467304