Imposition of penalty u/s 271(1)(c) without specifying the limb is bad-in-law

Unitech Realty Pvt Ltd Vs DCIT (ITAT Delhi) ITAT Delhi held that penalty notice under section 271(1)(c) without specifying the limb is vague and ambiguous, accordingly, penalty proceedings not sustainable. Facts- The assessment was completed on 22.12.2017 u/s 143(3) of the Act based upon the request of assessee wherein it was requested by the assessee that the assessee in good faith and, to avoid undue litigation, harassment and, to buy peace of mind is willing to get assessed at NIL income instead of declared loss of Rs. 17,87,88,640/- subject to the condition that no penalty proceedings woul...