Penalty Proceedings u/s 271(1)(c) Invalid if Initiated and Levied for Different Reasons, Ensuring Legal Consistency.

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....Penalty u/s 271(1)(c) - Validity of notice - It is a well settled proposition of law that penalty cannot be initiated for the limb, which is different from the limb for which proposed penalty proceedings has been initiated. Further, if the penalty proceedings has been initiated for one limb and levied under different limb, then the whole penalty proceedings become vitiate. - AT....