Ambiguity of charge sufficient to vitiate Section 271(1)(c) Penalty proceedings

I.G. International Pvt  Ltd  Vs ACIT (ITAT Mumbai) The case of I.G. International Pvt Ltd Vs ACIT, brought before ITAT Mumbai, delves into a pivotal aspect of penalty proceedings under section 271(1)(c) of the Income Tax Act, 1961. The contention revolves around the issuance of an unambiguous notice by the Assessing Officer, focusing on whether the notice was defective, thereby vitiating subsequent penalty proceedings. Representing the assessee, Shri Ashok Mehta argued that the notice under section 274 read with section 271(1)(c) of the Act was defective as it cited both limbs of section 271...