Sonpal Singh Pal Singh Saini v. ITO (2023) 102 ITR 32 (SN) (Mum.)(Trib)

S. 271(1)(c): Penalty-Concealment-Notice-AO had not struck off the inapplicable portion as to whether the levy of penalty was for concealment of income or for furnishing of inaccurate particulars of income-Penalty is not valid.[S.274]

The penalty notice and levy of penalty were liable to be quashed as the AO had not struck off the inapplicable portion in the notice.   followed: Mohd. Farhan A. Shaikh v. Dy. CIT (2021) 434 ITR 1 (Bom.) (HC)  (AY.2009-10)

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