https://www.taxtmi.com/caselaws?id=470016 A penalty notice under Section 271(1)(c) must identify whether the allegation concerns concealment of income or furnishing inaccurate particulars. Where the notice leaves both limbs unselected, it fails to communicate the precise charge and is treated as vague. The defect is not cured merely because the assessment order records satisfaction for initiating penalty proceedings. The resulting penalty proceedings are therefore vitiated, and the penalty cannot be sustained. The material discusses deletion of the penalty in favour of the assessee under the jurisdictional Full Bench principle applied by the Tribunal. en-us Wed, 12 Mar 2025 00:00:00 +0530 Mon, 13 Jul 2026 18:58:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470016 A penalty notice under Section 271(1)(c) must identify whether the allegation concerns concealment of income or furnishing inaccurate particulars. Where the notice leaves both limbs unselected, it fails to communicate the precise charge and is treated as vague. The defect is not cured merely because the assessment order records satisfaction for initiating penalty proceedings. The resulting penalty proceedings are therefore vitiated, and the penalty cannot be sustained. The material discusses deletion of the penalty in favour of the assessee under the jurisdictional Full Bench principle applied by the Tribunal. Case-Laws Income Tax Wed, 12 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470016