S. 271(1)(c) : Penalty–Concealment-Non-striking off of the irrelevant part while issuing notice under section 271(1)(c) of the Income-tax Act,- Order is bad in law-Assessee must be informed of the grounds of the penalty proceedings only through statutory notice. An omnibus notice suffers from the vice of vagueness. [S. 274]

A Full Bench of the Hon’ble Bombay High Court–Goa Bench in the case of Mr. Mohd. Farhan A. Shaikh v. ACIT TA No. 51 & 57 of 2012 dated March 11, 2021 (FB) (Bom.)(HC) (AY. 2006 -07 , 2007 -08 ) , while dealing with the issue of non-striking off of the irrelevant part while issuing Notice under section 271(1)(c) of the Income-tax Act, 1961held that the assessee must be informed of the grounds of the penalty proceedings only through statutory notice. An omnibus notice suffers from the vice of vagueness.

CIT v. Kaushalya (Smt ) (1995] 216 ITR 660 (Bom)(HC) distinguished

Ventura Textiles Ltd. v. CIT [2020] 426 ITR 478 (Bom)(HC) distinguished

Dilip N. Shroff v. JCIT [2007] 291 ITR 519 (SC) followed

The above-mentioned case of Mr. Mohd. Farhan A. Shaikh (Supra) has been followed by the Hon’ble Income-tax Appellate Tribunal – Pune Bench in the case of Shrivallabh V. Shete v. DCIT ITA No.538-39/PUN/2018 dated May 18, 2021 , Vijay Mohan Harde v. ACIT ITA No.588/PUN/2017 dated May 17, 2021, and ACIT v. Shri Vithalrao Rangnathrao Ambarwadikar ITA No.1547/PUN/2017 dated April 26, 2021.