Tax Penalty Imposed Under Wrong Provision Deemed Unsustainable Due to Lack of Specificity in AO's Standard Proforma Use.

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....Penalty u/s 271(1)(c) - AO initiated penalty on one limb of section 271(1)(c) and had imposed penalty on another limb - Third Member has upheld the view of AM that the standard proforma without striking of the relevant clauses will lead to an inference as to non-application of mind by AO and penalty is not sustainable....