The Assessing Officer had issued notice u/s 274 to levy penalty 271(1)(c) for concealment of income or furnishing inaccurate particulars to levy penalty for disallowance of interest and certain other business expenses, without striking off any of the aforesaid limbs. The Tribunal following the decisions in Dilip N. Shroff v. JCIT  (2007) 291 ITR 519 (SC) and the dismissal of the Special Leave Petition in SSA’s Emerald Meadows (2016) 73 taxmann.com 248 (SC)/ 366 ITR 13 (SC) (St)   held that as the AO did not strike off the irrelevant words, the penalty proceedings were without application of mind and thus unsustainable. (AY. 2010-11)