Penalty notice without specifying that it is for ‘furnishing of inaccurate particulars of income’ or for ‘concealment of income’ is fatal

 Assessing Officer should be clear as to which of the two limbs under which penalty is imposable, has been contravened or indicate that both have been contravened while initiating penalty proceedings. It cannot be that the initiation would be only on one limb i.e. for furnishing inaccurate particulars of income while imposition of penalty on the other limb i.e. concealment of income. RELEVANT EXTRACT OF THE JUDGMENT IS AS FOLLOWS:-  3 The impugned order of the Tribunal deleted the penalty imposed upon the Respondent­ Assessee. This by holding that the initiation of penalty under Section 27...