Initiation of penalty proceedings u/s 271(1)(c) without specifying basis makes such proceedings void -ab-initio

Brief of the case:

• The ITAT Bangalore in the case of Shri E. Krishnappa vs. ITO held that initiation of penalty proceedings u/s 271(1)(c) without mentioning its basis i.e. concealment of income or furnishing inaccurate particulars or both would make the proceedings illegal because AO’s satisfaction of the existence of the grounds mentioned in Section 271(1)(c) is a mandatory for initiation of proceedings.
• The additional ground can be admitted by the tribunal if it challenges the very legality

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