Section 271(1)(c) Penalty Quashed: Omnibus Notice Without Specific Charge Invalid

Sudesh Gupta Vs ACIT (ITAT Delhi) The appeal filed by Sudesh Gupta against the CIT(A) order dated November 8, 2019, involved a penalty of Rs. 13,60,455 under Section 271(1)(c) of the Income Tax Act for the assessment year 2013-14. The Assessee argued that the addition made under Section 2(22)(e) concerning deemed dividends was wrongly treated as concealment of income, especially since a similar addition had been made in the hands of another entity, Biggesto Technologies Ltd., for the same amount and under the same circumstances. The Assessee contended that this duplication of the same addition...