Section 271(1)(c) Penalty Invalid Due to Ambiguous Satisfaction Recorded by AO

Shiva Preservation Pvt. Ltd. Vs ITO (ITAT Agra) Penalty Invalid When Both Charges Are Clubbed- Concealment vs Inaccurate Particulars — ITAT Says AO Must Choose One, Not Both- ITAT Agra Deletes 271(1)(c) Agra Tribunal deleted the penalty u/s 271(1)(c) relating to an addition of ₹4,25,000 made as unexplained cash credit u/s 68 towards share application money. AO, in both the assessment order & the penalty notice u/s 274, stated that the Assessee had “concealed income & furnished inaccurate particulars”, thereby invoking both limbs of section 271(1)(c). The quantum addition had al...