2021 (3) TMI 99

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....ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeal has been fi led by the assessee against the order of the ld. CIT(A)-LTU, New Delhi dated 17.07.2013. 2. Following grounds have been raised by the assessee: 1. "That the impugned order of CIT (Appeals), LTU, New Delhi is bad in law and wrong on the facts and in the circumstances of the case and legal position. ....

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....5. That on the facts and in the circumstances of the case and the legal position, the learned CIT (Appeals) has erred in confirming the penalty levied u/s 271(1)(c) in respect of addition on account of miscellaneous expenditure incurred for increase in authorized capital amounting to Rs. 41,012/-. 6. That the appellant, craves, leave to add/alter/delete/amend any ground(s) of appeal befor....

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....ome" or furnished "inaccurate particulars of income" and on the basis of such satisfaction a show cause notice has to be issued under section 274 of the Act to the assessee specifying the addition/ disallowance in respect of which penalty is sought to be imposed and also the precise charge/ ground on which penalty is proposed to be imposed thereon. It was argued that notice issued under section 27....

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.... Manjunatha Cotton and Ginning Factory: 359 ITR 565 held that notice under section 274 should specifically state the grounds mentioned in section 271(1)(c) of the Act, i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. Sending printed form where all the grounds mentioned in section 271 are mentioned would not satisfy requirement of law. 8. The ju....