Penalty u/s 271(1)(c) Not Warranted Due to Defective Notice and Limitation Issues u/s 275.

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....Levy of penalty u/s 271(1)(c) - Defective notice - non specification of charge - Notice as barred by limitation u/s 275 - mere non-acceptance of the explanation so submitted by the assessee can be made a basis for addition in the quantum proceedings, however, the same cannot result in levy of penalty u/s 271(1)(c) - AT....