Imposition of penalty U/s. 271(1)(c) on defective show cause notice without specifying charge against assessee cannot be sustained

M/s. Swarn Ganga Gold Traders (P) Ltd. Vs. I.T.O. (ITAT Kolkata) Issuance of notice is an administrative device for informing the assessee about the proposal to levy penalty in order to enable him to explain as to why it should not be done. Mere mistake in the language used or mere non-striking of the inaccurate portion cannot by itself invalidate the notice. The Tribunal Benches at Mumbai and Patna being subordinate to the Honorable Bombay High Court and Patna High Court are bound to follow the aforesaid view. The Tribunal Benches at Bangalore have to follow the decision of the Honorable Karn...