Non-striking on irrelevant limb u/s 271(1)(c) vitiates entire penalty proceedings

DCIT Vs Global Cricket Corpn Pte Ltd. (ITAT Mumbai) ITAT Mumbai held that as the assessee should be aware of the exact charge for which the penalty proceeding has been initiated, non-striking on the irrelevant limb under section 271(1)(c) of the Income Tax Act vitiates the entire penalty proceedings. Facts- The assessee company is incorporated in Singapore and has obtained Worldwide Media and sponsorship right with regard to various cricketing events from 2000 to 2007 and had earned income from granting of broadcasting and sponsorship rights to various broad casters and sponsors. The assessee ...