AO’s Failure to Specify Section 271(1)(c) Charge Detrimental to Penalty Proceedings

PCIT Vs Modi Rubber Ltd. (Delhi High Court) Introduction: The Delhi High Court, in the case of Principal Commissioner of Income Tax (PCIT) vs. Modi Rubber Ltd., addressed an appeal related to Assessment Year (AY) 2003-04. The primary issue revolved around the initiation and imposition of a penalty under Section 271(1)(c) of the Income Tax Act, 1961. The court scrutinized whether the failure of the Assessing Officer (AO) to specify the exact charge under the section is detrimental to the penalty proceedings. Background: The appeal sought to challenge the order passed by the Income Tax Appellate...