https://www.taxtmi.com/caselaws?id=788134 A penalty notice invoking both limbs of section 271(1)(c) without specifying which limb applied or striking off the inapplicable limb was held defective; the procedural requirement of limb-specific notice is decisive and renders any consequent penalty vulnerable irrespective of the merits of underlying income additions or application of section 145(3). Because the notice failed to identify the particular limb under which proceedings were initiated, the penalty under section 271(1)(c) was quashed and the appeal allowed in favour of the assessee. en-us Fri, 13 Mar 2026 00:00:00 +0530 Tue, 17 Mar 2026 08:23:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788134 A penalty notice invoking both limbs of section 271(1)(c) without specifying which limb applied or striking off the inapplicable limb was held defective; the procedural requirement of limb-specific notice is decisive and renders any consequent penalty vulnerable irrespective of the merits of underlying income additions or application of section 145(3). Because the notice failed to identify the particular limb under which proceedings were initiated, the penalty under section 271(1)(c) was quashed and the appeal allowed in favour of the assessee. Case-Laws Income Tax Fri, 13 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788134