Notice issued by AO without specifying grounds of penalty is not valid

Advertisement Smt. Jayalakshmi Vs ITO (ITAT Bangalore) The only disputed issue prima facie is in respect of levy of penalty u/s 271(1)(c) of the Act. The contention of the learned AR is that the AO has passed the penalty order without application of mind and referred to page 39 & 40 of the paper book where notice u/s 274 r.w.s. 271(1)(c) dated 31/12/2007 is enclosed. On perusal of the notice at page 40, as demonstrated by the learned AR, the AO has initiated penalty proceedings both for concealment of particulars of income and furnishing of inaccurate particulars of such income. We ar...