The penalty notice under section 274, read with section 271(1)(c), did not specify the limb under which the penalty was sought to be imposed,  i.e., whether for concealment of income or for the reason that the Assessee had furnished inaccurate particulars. The Court held that penalty proceedings entail civil consequences for the Assessee. When initiating penalty proceedings, the AO must apply his mind to the material particulars and indicate what is alleged against the Assessee. The AO has an obligation to specify which limb of the said provision is being invoked. In the case of concealment, a higher burden is imposed on the Assessee than furnishing inaccurate particulars. Therefore, the AO must indicate the limb under which penalty proceedings are initiated against the Assessee.(AY. 2012-13)  (AY.2004-05)