https://www.taxtmi.com/caselaws?id=471015 Penalty proceedings under Section 271(1)(c) require a notice under Section 274 to specify whether the charge is concealment of income or furnishing inaccurate particulars. These are distinct defaults, and retaining both limbs in a standard printed notice without striking out the inapplicable limb fails to provide a clear opportunity to respond. Such ambiguity indicates non-application of mind and breaches principles of natural justice. Because penalty proceedings are separate from assessment proceedings, material in the assessment record cannot cure a defective penalty notice. An unspecified notice is invalid and the consequential penalty is unsustainable. en-us Wed, 11 Apr 2018 00:00:00 +0530 Tue, 18 Aug 2026 14:37:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471015 Penalty proceedings under Section 271(1)(c) require a notice under Section 274 to specify whether the charge is concealment of income or furnishing inaccurate particulars. These are distinct defaults, and retaining both limbs in a standard printed notice without striking out the inapplicable limb fails to provide a clear opportunity to respond. Such ambiguity indicates non-application of mind and breaches principles of natural justice. Because penalty proceedings are separate from assessment proceedings, material in the assessment record cannot cure a defective penalty notice. An unspecified notice is invalid and the consequential penalty is unsustainable. Case-Laws Income Tax Wed, 11 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471015