https://www.taxtmi.com/caselaws?id=470614 A penalty under Section 271(1)(c) cannot rest on a show-cause notice that fails to specify whether the alleged default is concealment of income, furnishing inaccurate particulars, or both. An ambiguous notice does not clearly communicate the precise charge and is therefore defective. Applying the binding Full Bench ruling, the Tribunal correctly treated the penalty as invalid because the notice lacked a clear and unambiguous basis for initiating penalty proceedings. No substantial question of law arose, and the issue was resolved in favour of the assessee. en-us Thu, 06 Nov 2025 00:00:00 +0530 Sat, 01 Aug 2026 10:04:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470614 A penalty under Section 271(1)(c) cannot rest on a show-cause notice that fails to specify whether the alleged default is concealment of income, furnishing inaccurate particulars, or both. An ambiguous notice does not clearly communicate the precise charge and is therefore defective. Applying the binding Full Bench ruling, the Tribunal correctly treated the penalty as invalid because the notice lacked a clear and unambiguous basis for initiating penalty proceedings. No substantial question of law arose, and the issue was resolved in favour of the assessee. Case-Laws Income Tax Thu, 06 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470614