Defective U/s 271(1)(c) Notice Makes Penalty Void; No Merger on SLP Dismissal – ITAT Chennai

RR Industries Ltd Vs DCIT (ITAT Chennai) Defective Penalty Notice = Penalty Void – Failure to Strike Off Limb u/s 271(1)(c) Held Fatal – Doctrine of Merger Not Applicable to SLP Dismissal – ITAT Chennai ITAT Chennai deleted penalty u/s 271(1)(c) holding that show-cause notice issued u/s 274 was vague & invalid where AO failed to specify whether charge was “concealment” or “furnishing inaccurate particulars”. Tribunal relied on jurisdictional HC ruling in Babuji Jacob & held that non-application of mind in penalty notice vitiates entire proceedings. ITAT rejected Revenue�...