Penalty notice u/s. 274 r.w.s 271(1)(c) not specifying limb under which penalty proceeding is initiated is invalid

K. World Developers Pvt. Ltd. Vs ACIT (ITAT Delhi) ITAT Delhi held that issuance of notice under section 274 r.w.s. 271(1)(c) of the Income Tax Act without specifying the particular limb under which the penalty proceedings have been initiated concludes that the notice is issued in a stereotyped manner without applying mind and accordingly imposition of penalty is bad in law. Facts- AO noticed that the Assessee has received the share capital of Rs.35,00,000/- from Ankay Associates Pvt., a company found to be controlled and managed by one Shri Anil Agarwal who had admitted in his statement that ...