2025 (11) TMI 2043

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....spondent: Mr. Rahul Hakani. P.C.:- 1. Heard learned counsel for the parties. 2. Mr. Gupta proposes the following question, which according to him, constitutes a substantial question of law:- B. Whether on the facts and circumstances of the case and in law, the Hon'ble ITAT is correct in deleting the penalty u/s 271(1)(c) of the Income Tax Act, 1961 on technical ground by hold....

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....f imposition of any penalty. In this case, on the perusal of the show cause notice, it is not at all clear whether penalty was proposed to be imposed based on concealment, disclosure of incorrect particulars or both. Therefore, the vice pointed out by the Full Bench, equally applies to the show cause notice which was the foundation of imposition of the impugned penalty. The attempt to distinguish ....