Held that the notice which does not specify whether the AO has initiated the penalty for under-reporting of income as per sub-ss. (1) to (7) of s. 270A or for misreporting of income as per sub-ss. (8) to (9) thereof is a vague notice which does not satisfy the requirement of law and, therefore, the levy of penalty is fragile in the eyes of law and is ab initio void. (AY. 2018-19, 2020-21)
St. Joseph’s Educational Trust v. DCIT (2025) 236 TTJ 507 / 175 taxmann.com 284 / (2026) 133 ITR 328 (Chennai) (Trib) St.Joseph’s Institute of Science & Technology Trust v. Dy.CIT 2025) 236 TTJ 507 / 175 taxmann.com 284 / (2026) 133 ITR 328 (Chennai) (Trib)
S. 270A: Penalty for under-reporting and misreporting of income-Non-specification of charge/fault in the show-cause notice-Absence of proper charge vitiates the penalty notices-Levy of penalty was quashed. [S. 274]
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