Held  that the notice was in the nature of an omnibus show-cause notice issued without deleting or striking out the inapplicable part. The penalty order passed under section 271(1)(c) of the Act also did not spell out which limb of section 271(1)(c) of the Act was attracted for levy of penalty. Since show-cause notice itself did not spell out clearly as to what fault the assessee was being proceeded against for levy of penalty, the notice itself was bad in law, and consequently the penalty levied was vitiated.  That moreover, in the quantum assessment the estimated addition of 100 per cent. of purchases was made by the Assessing Officer, which was reduced to 30 per cent. of the purchases by the Commissioner (Appeals). In such a scenario, penalty under section 271(1)(c) of the Act was not warranted because estimated addition involved inherent subjectivity. (AY.2010-11)