https://www.taxtmi.com/caselaws?id=470140 A penalty notice issued under Section 274 read with Section 271AAB(1) must specify the applicable clause-(a), (b) or (c)-because each prescribes distinct penalty consequences. Identifying the proposed clause gives the assessee a definite charge and a meaningful opportunity to respond. An unspecified notice is defective and cannot support a search-related penalty under Section 271AAB. The note distinguishes contrary authority where the defective-notice objection was raised for the first time before the High Court, unlike an objection raised and adjudicated before the first appellate authority. en-us Fri, 20 Feb 2026 00:00:00 +0530 Thu, 16 Jul 2026 19:02:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470140 A penalty notice issued under Section 274 read with Section 271AAB(1) must specify the applicable clause-(a), (b) or (c)-because each prescribes distinct penalty consequences. Identifying the proposed clause gives the assessee a definite charge and a meaningful opportunity to respond. An unspecified notice is defective and cannot support a search-related penalty under Section 271AAB. The note distinguishes contrary authority where the defective-notice objection was raised for the first time before the High Court, unlike an objection raised and adjudicated before the first appellate authority. Case-Laws Income Tax Fri, 20 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470140