Notice proposing penalty u/s. 271(1)(c) without specifying limb is bad-in-law

PCIT-7 Vs Quippo Telecom Infrastructure Pvt. Ltd. (Delhi High Court) Delhi High Court held that issuance of notice for initiating penalty proceedings under section 271(1)(c) of the Income Tax Act without specifying the limb under which the penalty was proposed to be levied is bad-in-law. Accordingly, appeal of revenue dismissed. Facts- AO disallowed the Assessee’s claim for expenditure of ₹2,50,00,000/- for availing professional services and further disallowed a sum of ₹223,03,31,321/- on account of interest claimed by the Assessee u/s. 36(1)(iii) of the Act and assessed the total income...