Section 271(1)(c) Penalty Invalid if AO Omits Specific Reason for Imposition

Malla Appalaraju Vs ITO ( ITAT Visakhapatnam) The Income Tax Appellate Tribunal (ITAT), Visakhapatnam, has ruled in favor of Malla Appalaraju, setting aside a penalty imposed under Section 271(1)(c) of the Income Tax Act, 1961. The penalty of ₹12,23,211 was levied for an alleged unexplained investment under Section 69. The tribunal found that the penalty notice issued by the Assessing Officer (AO) was defective as it failed to specify whether the penalty was for “concealment of income” or for “furnishing inaccurate particulars of income.” The case originated from an a...