https://www.taxtmi.com/caselaws?id=796251 A penalty notice under section 271(1)(c) must clearly specify whether the charge is concealment of income or furnishing inaccurate particulars, as these are distinct statutory limbs. Penalty proceedings remain independent of assessment proceedings, so an omnibus notice cannot be cured by the assessment order or by changing the basis in the penalty order. Where the notice alleged concealment but the penalty order proceeded for furnishing inaccurate particulars, the absence of a definite and consistent charge invalidated the proceedings. The penalty was therefore quashed. en-us Wed, 27 May 2026 00:00:00 +0530 Mon, 03 Aug 2026 08:20:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796251 A penalty notice under section 271(1)(c) must clearly specify whether the charge is concealment of income or furnishing inaccurate particulars, as these are distinct statutory limbs. Penalty proceedings remain independent of assessment proceedings, so an omnibus notice cannot be cured by the assessment order or by changing the basis in the penalty order. Where the notice alleged concealment but the penalty order proceeded for furnishing inaccurate particulars, the absence of a definite and consistent charge invalidated the proceedings. The penalty was therefore quashed. Case-Laws Income Tax Wed, 27 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796251