Penalty u/s 271 (1) (c) is not maintainable if charges are not specific– ITAT

Brief of the Case Mumbai ITAT held In the case of Shri Hafeez S Contractor vs. ACIT that penalty u/s 271(1) (c) cannot be imposed in those cases where no specific charges are mentioned in penalty notice. In the given case the AO has not specified that as to which limb the notice was issued, i.e., whether it is issued for concealment of particulars of income or furnishing of inaccurate particulars of income. Facts of the Case During the course of search proceedings, it was noticed that the assessee has claimed expenditure in respect of commission paid to two parties namely (a) M/s Nischal Corpo...