https://www.taxtmi.com/caselaws?id=793945 In quantum appeals, substantial delay was not condoned because the explanations did not show sufficient cause, so those appeals were dismissed as time-barred. In penalty appeals, short delays of 25 and 27 days were condoned on a liberal approach in favour of substantial justice, and the appeals were admitted. On merits, penalty notices under section 274 read with section 271(1)(c) were held invalid because they did not specify whether the charge was concealment of income or furnishing inaccurate particulars, and the irrelevant limb was not struck off. The omnibus notices were treated as ambiguous, contrary to fair notice and natural justice, so the penalty was deleted. en-us Tue, 23 Jun 2026 00:00:00 +0530 Fri, 26 Jun 2026 07:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793945 In quantum appeals, substantial delay was not condoned because the explanations did not show sufficient cause, so those appeals were dismissed as time-barred. In penalty appeals, short delays of 25 and 27 days were condoned on a liberal approach in favour of substantial justice, and the appeals were admitted. On merits, penalty notices under section 274 read with section 271(1)(c) were held invalid because they did not specify whether the charge was concealment of income or furnishing inaccurate particulars, and the irrelevant limb was not struck off. The omnibus notices were treated as ambiguous, contrary to fair notice and natural justice, so the penalty was deleted. Case-Laws Income Tax Tue, 23 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793945