No Section 271(1)(c) penalty if AO not indicate which limb is attracted

PCIT Vs Shyam Sunder Jindal (Delhi High Court) Introduction: The Delhi High Court, in the case of Principal Commissioner of Income Tax (PCIT) vs. Shyam Sunder Jindal, addressed appeals related to Assessment Years (AYs) 2011-12, 2008-09, 2010-11, and 2009-10. The core issue revolved around the imposition of a penalty under Section 271(1)(c) of the Income Tax Act, 1961, and whether the penalty notices provided sufficient specificity regarding the grounds for imposition. Background: The appeals challenged the common order passed by the Income Tax Appellate Tribunal in June 2021. Penalty Notices a...