https://www.taxtmi.com/caselaws?id=797485 Penalty proceedings under Section 271(1)(c) require a statutory notice that identifies the specific charge: concealment of income or furnishing inaccurate particulars. These are independent grounds, and retaining both alternatives in a general notice denies the assessee a meaningful opportunity to respond. The defect is jurisdictional rather than a curable procedural irregularity, so a penalty founded on an unspecified charge cannot be sustained. Requirements concerning recording satisfaction in the assessment order and referring to statutory Explanations are distinct from the requirement to specify the applicable penalty limb in the notice. en-us Wed, 19 Aug 2026 00:00:00 +0530 Sat, 22 Aug 2026 10:33:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797485 Penalty proceedings under Section 271(1)(c) require a statutory notice that identifies the specific charge: concealment of income or furnishing inaccurate particulars. These are independent grounds, and retaining both alternatives in a general notice denies the assessee a meaningful opportunity to respond. The defect is jurisdictional rather than a curable procedural irregularity, so a penalty founded on an unspecified charge cannot be sustained. Requirements concerning recording satisfaction in the assessment order and referring to statutory Explanations are distinct from the requirement to specify the applicable penalty limb in the notice. Case-Laws Income Tax Wed, 19 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797485