Penalty Notices Must Be Specific: Assessment Order Allegations Don't Fix Defects u/ss 271 and 292B.

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....Penalty u/s 271 - Defective notice - the allegation should be specific and clear in the penalty notice also because the assessee has to submit reply in the course of penalty proceedings on the basis of allegation in the penalty notice only and not on the basis of allegation in the Assessment Order and therefore, even if specific allegation is made by the AO in the Assessment Order, the defect in the penalty notice does not get rectified even u/s 292B - AT....