PCIT v. Blackroak Securities (P.) Ltd. (2024) 297 Taxman 69 (Delhi)(HC)

S. 271(1)(c) : Penalty-Concealment-Not specifying the charge-Order of Tribunal quashing the penalty is affirmed.[S.260A]

Held that Assessing Officer while initiating penalty proceedings under section 271(1)(c), should have alluded to limb under which penalty is proposed to be levied, i.e., should have stipulated as to whether penalty was proposed to be imposed on assessee for concealment of particulars of its income, or furnishing inaccurate particulars. Assessing Officer had not specified under which limb of section 271(1)(c) penalty was initiated, Tribunal had rightly set aside penalty order. (AY. 2014-15)