Section 271(1)(c) Penalty Proceedings Failed Because Levy Exceeded Scope of Notice

Corteva Agriscience Seeds Pvt. Ltd. Vs Additional/Joint/Deputy ACIT (ITAT Delhi) ITAT Delhi quashes ₹99.77 cr penalty: Inconsistent charge of concealment vs. inaccurate particulars vitiates 271(1)(c) Delhi Tribunal allowed the assessee’s appeal and quashed the penalty of ₹99.77 crore levied u/s 271(1)(c). The Tribunal noted that while the show-cause notice & initiation of penalty proceedings alleged furnishing of “inaccurate particulars of income”, the final penalty order proceeded on the footing that both concealment of income and furnishing of inaccurate particulars were prese...