https://www.taxtmi.com/caselaws?id=467304 Penalty proceedings for concealment of income or furnishing inaccurate particulars require a notice that clearly identifies the specific charge. A notice issued under section 274 read with section 271(1)(c) that retains both alternative limbs without striking out the inapplicable limb is ambiguous and denies the assessee a clear opportunity to defend. Such ambiguity vitiates the penalty proceedings because the penal allegation must be specific and unequivocal. Applying this requirement where the Assessing Officer failed to specify the invoked limb, the penalty order was quashed. 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 Penalty proceedings for concealment of income or furnishing inaccurate particulars require a notice that clearly identifies the specific charge. A notice issued under section 274 read with section 271(1)(c) that retains both alternative limbs without striking out the inapplicable limb is ambiguous and denies the assessee a clear opportunity to defend. Such ambiguity vitiates the penalty proceedings because the penal allegation must be specific and unequivocal. Applying this requirement where the Assessing Officer failed to specify the invoked limb, the penalty order was quashed. Case-Laws Income Tax Mon, 27 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467304