Omnibus Penalty Notice without Striking Irrelevant Limb Held Invalid

Toshiba Water Solutions (P) Ltd. Vs ACIT (ITAT Delhi) Omnibus Notice without Striking Irrelevant Limb Held Invalid- ITAT Delhi Quashes Penalty u/s 271(1)(c) for Defective Notice Assessee had filed return declaring income of ₹5.64 crore. AO passed assessment order u/s 143(3) making additions & computing income at ₹8.07 crore. Consequent penalty proceedings culminated in an order dated 28.04.2023 levying penalty u/s 271(1)(c), confirmed by CIT(A). Before Tribunal, the Assessee argued that penalty notice issued u/s 274 r.w.s. 271 was defective as the AO failed to strike off the irrelevant...