AO cannot be uncertain in penalty order as to concealment or furnishing of inaccurate particulars of income

HPCL Mittal Energy Ltd. Vs Addl. CIT (ITAT Amritsar)

The moot question is that what should be the nature of specification of a charge by the AO at the stage of initiation of penalty proceedings and at the time of passing the penalty order. Is the AO required to specify in the penalty notice/order as to whether it is a case of `concealment of particulars of income’; or `furnishing of inaccurate particulars of income’; or both of them, which can be expressed by using the word `and’ between the two expressions. When the A

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