https://www.taxtmi.com/caselaws?id=797485 Penalty proceedings under Section 271(1)(c) require the notice to specify whether the charge concerns concealment of income or furnishing inaccurate particulars of income. These are distinct statutory alternatives, and retaining both without identifying the applicable limb denies the assessee an effective opportunity to answer the precise allegation. A general satisfaction recorded in the assessment order does not cure this defect. Principles concerning satisfaction recording or omission to cite statutory explanations do not address such ambiguity. An unspecified notice is invalid, and penalty cannot be sustained on its basis. en-us Mon, 17 Aug 2026 00:00:00 +0530 Mon, 31 Aug 2026 12:49:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797485 Penalty proceedings under Section 271(1)(c) require the notice to specify whether the charge concerns concealment of income or furnishing inaccurate particulars of income. These are distinct statutory alternatives, and retaining both without identifying the applicable limb denies the assessee an effective opportunity to answer the precise allegation. A general satisfaction recorded in the assessment order does not cure this defect. Principles concerning satisfaction recording or omission to cite statutory explanations do not address such ambiguity. An unspecified notice is invalid, and penalty cannot be sustained on its basis. Case-Laws Income Tax Mon, 17 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797485