Section 271(1)(c) Penalty for Income Concealment Invalid on Flawed Notice

PCIT Vs Dr. Murari Mohan Koley (Calcutta High Court) The case of PCIT vs. Dr. Murari Mohan Koley before the Calcutta High Court addressed a fundamental procedural issue in the imposition of penalties under Section 271(1)(c) of the Income Tax Act, 1961. The core issue was whether a penalty could be legally sustained if the initial show-cause notice issued to the assessee was defective because it did not specify the exact charge. The penalty in this case was levied for five assessment years: 2004-05, 2005-06, 2006-07, 2007-08, and 2009-10. Factual Background The tax authorities initiated penalty...