ITAT Quashes Section 271(1)(c) Penalty for Non-Strike of Limb in Notice & Admission of Substantial Question of Law

Ambrish Manoj Dhupelia Vs DCIT (ITAT Mumbai) Summary: The case involves three appeals filed by members of the same family against penalty orders issued under Section 271(1)(c) of the Income Tax Act for the Assessment Year 2002-03. These penalties were contested on the grounds that the notices issued under Section 274 of the Act did not specify whether the penalties were for concealment of income or furnishing inaccurate particulars. This procedural defect, as argued by the appellants, rendered the penalty orders invalid. Furthermore, they relied on a precedent set by the Bombay High Court in ...