https://www.taxtmi.com/caselaws?id=795500 Penalty under section 271(1)(c) cannot rest on an assessment completed without jurisdiction: where one officer issued the section 143(2) notice and another completed the assessment, the assessment was treated as invalid, allowing that defect to be raised in penalty proceedings and preventing the penalty from surviving. Separately, a section 274 notice that retains both concealment and furnishing inaccurate particulars charges without identifying the alleged default fails to communicate the precise charge and indicates non-application of mind. Such defective initiation vitiates the penalty proceedings and consequential penalty order. en-us Tue, 16 Jun 2026 00:00:00 +0530 Thu, 23 Jul 2026 08:42:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795500 Penalty under section 271(1)(c) cannot rest on an assessment completed without jurisdiction: where one officer issued the section 143(2) notice and another completed the assessment, the assessment was treated as invalid, allowing that defect to be raised in penalty proceedings and preventing the penalty from surviving. Separately, a section 274 notice that retains both concealment and furnishing inaccurate particulars charges without identifying the alleged default fails to communicate the precise charge and indicates non-application of mind. Such defective initiation vitiates the penalty proceedings and consequential penalty order. Case-Laws Income Tax Tue, 16 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795500