Notice u/s 271(1)(1) Invalid: Ambiguity on Accusation Type Prevents Penalty Imposition in Tax Case.

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....Penalty u/s 271(1)(1) - validity of notice - there is no mention in the SCN, whether the assessee was guilty of having “furnished inaccurate particulars of income” or of having “concealed particulars of such income” - No penalty can be levied on the basis of defective notice - AT....