Held, that the notice was an omnibus show-cause notice as it did not strike off or delete the inapplicable portion. Such a generic notice betrayed a non-application of mind. Therefore, the penalty levied pursuant to such a notice was not legally sustainable in law. (AY. 2009-10 to 2013-14)
Shoreline Hotel Pvt. Ltd. v. Dy.CIT (2022) 94 ITR 18 (SN) (Mum.)(Trib.)
S. 271(1)(c) : Penalty-Concealment-Relevant limb specifying charge not struck off-Penalty not leviable.