https://www.taxtmi.com/caselaws?id=472935 Penalty notices issued under Sections 274 and 271(1)(c) must identify whether the proposed charge is concealment of income or furnishing inaccurate particulars. Retaining both statutory limbs without eliminating the inapplicable limb makes the notice vague, demonstrates non-application of mind, and vitiates the resulting penalty proceedings. A non-speaking refusal of special leave under Article 136 does not trigger merger or constitute a declaration of law under Article 141. It therefore does not displace applicable jurisdictional precedent on defective penalty notices. en-us Thu, 09 Jul 2026 00:00:00 +0530 Wed, 28 Oct 2026 22:40:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472935 Penalty notices issued under Sections 274 and 271(1)(c) must identify whether the proposed charge is concealment of income or furnishing inaccurate particulars. Retaining both statutory limbs without eliminating the inapplicable limb makes the notice vague, demonstrates non-application of mind, and vitiates the resulting penalty proceedings. A non-speaking refusal of special leave under Article 136 does not trigger merger or constitute a declaration of law under Article 141. It therefore does not displace applicable jurisdictional precedent on defective penalty notices. Case-Laws Income Tax Thu, 09 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472935