Allowing the appeal the Tribunal held that  the Assessing Officer had not mentioned under which limb of section 271(1)(c) of the Act penalty was to be levied against the assessee. According to section 274 of the Act, no order imposing a penalty shall be passed unless the assessee has been heard or has been given a reasonable opportunity of being heard. The Assessing Officer had issued invalid and defective notices under section 271(1)(c) of the Act read with section 274 of the Act and the entire penalty proceedings were vitiated and liable to be quashed.(AY. 2009-10 to 2012-13)