AO Should Specify Proper Limb under Section 271(1)(c) of Income Tax Act

Pranav Kumar Vs DCIT (ITAT Delhi) We have carefully considered the rival submissions made by both the sides and perused the material on record. The issue in the present appeal is with respect to levy of penalty under section 271(1)(c) of the I.T. Act, 1961. In the present appeal, the show cause notice dated 27.11.2017 that was issued under section 274 read with section 271(1)(c) of the I.T. Act, 1961 reveals that A.O. has not recorded any clear cut satisfaction as to whether the penalty under Section 271(1)(c) of the Act has been levied for concealment of income or for furnishing of inaccurate...