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    <title>2025 (3) TMI 1861 - ITAT MUMBAI</title>
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    <description>Penalty proceedings under section 271(1)(c) were treated as invalid where the show cause notice was a printed form that did not specify the exact limb and did not strike off the inapplicable portion. A later notice was mentioned, but its copy was not produced, so its contents could not be verified; the resulting uncertainty was resolved in favour of the assessee. Following the jurisdictional Full Bench view that such a defective notice vitiates penalty proceedings, the penalty could not be sustained.</description>
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      <description>Penalty proceedings under section 271(1)(c) were treated as invalid where the show cause notice was a printed form that did not specify the exact limb and did not strike off the inapplicable portion. A later notice was mentioned, but its copy was not produced, so its contents could not be verified; the resulting uncertainty was resolved in favour of the assessee. Following the jurisdictional Full Bench view that such a defective notice vitiates penalty proceedings, the penalty could not be sustained.</description>
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