Penalty Notice Under Wrong Income Tax Act Provision Deemed Unsustainable Due to Ambiguity and Lack of Proper Consideration.

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....Notice of penalty u/s wrong provision of Act – The standard proforma without striking of the relevant clauses will lead to an inference as to non-application of mind - Penalty should be clear as to the limb for which it is levied and the position being unclear here the penalty is not sustainable - AT....