Notice not stating specific limb of Sec. 271(1)(c) cannot be sustained: ITAT Raipur

Ganesh Prasad Khetan Vs DCIT (ITAT Raipur) ITAT Raipur held that penalty u/s. 271(1)(c) of the Income Tax Act is liable to be struck down for the failure on the part of the A.O. to put the assessee to notice as regards the default for which penalty under Sec. 271(1)(c) was sought to be imposed. Facts- The assessee is an individual. The case of the assessee was subsequently reopened u/s. 147 r.w.s. 144B of the Act. Assessment u/s. 147 r.w.s. 144B of the Act was culminated on 26.03.2022, wherein penalty proceedings u/s.271(1)(c) of the Act were separately initiated by the A.O for “concealm...