Bogus Purchase: ITAT Quashes 271(1)(c) Penalty as Specific Limb not Mentioned

ACIT Vs Torane Ispat Udyog Private Limited (ITAT Mumbai)

No Specific Limb Mentioned, No Penalty – Defective Notice Cannot Be Cured by Section 292B – ITAT Deletes 271(1)(c) Penalty- Ambiguous 274 Notice Fatal

The Revenue appealed against the order of CIT(A), NFAC, Delhi dated 21.02.2025 deleting a penalty of ₹4,01,723 levied u/s 271(1)(c) for alleged concealment of income on bogus purchases. Assessee filed a cross objection, contending that the penalty notice was invalid as it did not specify the charge under which penalty was proposed.

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