In the notice issued u/s.274 r.w.s 271(1)(c) no specific limb of the penalty indicated i.e., whether it is for concealment of particulars of income or for furnishing of inaccurate particulars of income. The tribunal relied upon multiple jurisdictional HC and ITAT decisions on the same issue and held, that such notice is not sustainable in the eyes of law and illegal, as per the settled law.(AY. 2013-114)
Sudesh Gupta v. ACIT. [2025] 121 ITR 1/ 210 ITD 436 (Delhi) (Trib)
S. 271(1)(c) : Penalty-Concealment-No specific limb in penalty notice-Penalty order is set aside.[S. 274]
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