PCIT v. Sahara India Life Insurance Co. Ltd. (2021) 432 ITR 84 (Delhi) (HC)

S. 271(1)(c) : Penalty-Concealment-Notice-Not mentioning the specific charge for concealment of income or furnishing inaccurate particulars of income-Deletion of penalty is held to be justified.

Dismissing the appeal of the revenue the Court held that  the notice issued by the Assessing Officer was bad in law if it did not specify under which limb of section 271(1)(c) the penalty proceedings had been initiated, i. e., whether for concealment of particulars of income or for furnishing of inaccurate particulars of income. (AY. 2004-05, 2005-06, 2008-09, 2010-11)